Macoupin Energy, LLC - Illinois Environmental Protection Agency

Transcription

Macoupin Energy, LLC
Shay No. 1 Mine
National Pollutant Discharge Elimination
System (NPDES) Permit
Responsiveness Summary
Regarding
April 27, 2011 & March 11, 2014
Public Hearings
Illinois Environmental Protection Agency
Office of Community Relations
August 18, 2015
Macoupin Energy, LLC
Shay No. 1 Mine
National Pollutant Discharge Elimination System (NPDES) Permit
Responsiveness Summary
Table of Contents
Illinois EPA Permit Decision ........................................................................ 3
Pre-hearing Public Outreach ....................................................................... 3
Public Hearing of April 27, 2011 & March 11, 2014.................................... 4
Background of Facility Owner ..................................................................... 5
Responses to Comments, Questions and Concerns
NPDES Permit .................................................................................. 6
Water Quality Standards/Antidegradation Assessment ............. 19
Groundwater Issues ....................................................................... 29
Enforcement/Compliance Issues .................................................. 36
Site Remediation ............................................................................. 38
Reclamation .................................................................................... 38
Other Issues .................................................................................... 40
Acronyms and Initials ................................................................................ 43
Distribution of Responsiveness Summary .............................................. 45
Who to Contact for Answers ..................................................................... 45
Final August 18, 2015
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ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
Macoupin Energy, LLC.
Shay No. 1 Mine
Renewal of Permit
Permit Number IL0056022
ILLINOIS EPA PERMIT DECISION
On August 18, 2015, the Illinois Environmental Protection Agency approved a renewed
NPDES permit for Macoupin Energy, LLC.
The NPDES permit reflects the following changes since the last public notice:
1. Special Condition 17, which contained a chloride compliance schedule for Outfall
007 and plans to relocate the outfall, was removed from the permit. As a result,
effluent limits for Outfall 007 were modified to require that water quality standards
are to be met under all discharge conditions. Previously, mixing for Outfall 007
was to be allowed under precipitation-driven discharge events as described by
Special Conditions 13 and 16. These Special Conditions have now been
modified to only allow mixing for Outfalls 002 and 005.
2. Supplemental Construction Authorization No. 8107-10-1, (Page 19 of the draft
Permit), was revised to specify the water handling procedures relative to the
ground trenches and wick drains.
3. The permit was revised to reflect a maximum detection limit of 0.002 mg/L for
Selenium (Special Condition No. 20 in the draft permit).
PRE-HEARING PUBLIC OUTREACH
The notice of the April 27, 2011 NPDES permit public hearing was published in the
Macoupin County Enquirer Democrat on March 10, 17, and 24, 2011.
The notice of the March 11, 2014 NPDES permit public hearing was published in
Macoupin County Enquirer Democrat on January 23, 30 & February 6, 2014.
The hearing notices were mailed or e-mailed to:
a) The hearing officer list of those requesting to be notified of water hearings;
b) Macoupin county officials;
c) Municipal officials in Carlinville and Gillespie; and,
d) All who requested a hearing or filed comments on the public noticed permit.
The hearing notices were posted on the Illinois EPA website and are available at:
http://www.epa.illinois.gov/public-notices/2013/npdes-notices/index#macoupin-energy
Hearing notices were posted at the Illinois EPA headquarters in Springfield and in the
Marion Regional Office.
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April 27, 2011 and March 11, 2014 PUBLIC HEARING
Hearing Officer Dean Studer opened the hearing April 27, 2011, at 6:06 p.m. at the
Blackburn College – Olin Lecture Hall, 200 College Avenue, Carlinville, Illinois.
Hearing Officer Dean Studer opened the hearing March 11, 2014, at 5:04 p.m. at the
Carlinville Park District Building located at 859 Ramey Street, Carlinville, Illinois.
Illinois EPA Hearing Participants (4-27-2011 and 3-11-2014):
Stefanie Diers, Assistant Counsel, Bureau of Water
Brian Koch, Standards Section, Bureau of Water
Lynn Dunaway, Groundwater Section, Bureau of Water
Larry D. Crislip, Permit Section Manger, Mine Program, Bureau of Water
Comments and questions were received from the audience at both hearings.
Hearing Officer Dean Studer closed the hearing at 8:05 p.m. on April 27, 2011.
Hearing Officer Dean Studer closed the hearing at 7:05 p.m. on March 11, 2014.
Illinois EPA personnel were available before, during and after the hearings to meet with
elected officials, news media and concerned citizens.
Audience members representing neighbors, local government, businesses, miners, elected
officials, environmental groups, interested citizens, and Hillsboro Energy, L.L.C.,
participated at and/or attended the hearing. A court reporter prepared transcripts for both
public hearings which were posted on the Illinois EPA website and are available at:
The hearing record remained opened through May 27, 2011 for the April 27, 2011 hearing.
The hearing record remained open through April 10, 2014 for the March 11, 2014 hearing.
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BACKGROUND of Macoupin Energy, L. L. C.
Shay No. 1 Mine
The Illinois EPA Bureau of Water prepared a draft renewed National Pollutant Discharge
Elimination System (NPDES) permit with modifications for Macoupin Energy, L.L.C., Shay No.
1 Mine. The address of the discharger is 14300 Brushy Mound Road, Carlinville, Illinois 62626.
The facility is located in Macoupin County, approximately 7 miles south of Carlinville, Illinois
and discharges into Spanish Needle Creek and unnamed tributaries of Macoupin Creek and
Spanish Needle Creek.
The applicant operates an existing underground coal mine (SIC 1222). Mine operations result
in the discharge of wastewater classified as alkaline mine drainage, wastewater from the
preparation plant area and coal refuse disposal piles classified as acid mine drainage, and
stormwater and sanitary wastewater. Modifications included in the draft permit public noticed
on December 3, 2013 included the additions of various parcels totaling 42.5 acres for use of
facilities in support of the underground mining activities; reclassification of Outfall 003 and
Outfall 004 as stormwater discharges; elimination of Outfall 006; incorporation of modified
disposal plan to include underground disposal of fine coal refuse; and, a revision to the
reclamation plan for Refuse Area Numbers 5 and 6. These are modifications (included in the
December 3, 2013 public notice) since the previously public-noticed permit on November 18,
2010 (a hearing was held on April 27, 2011 regarding the 2010 public-noticed draft permit but
a final permit was not issued until now).
A Total Maximum Daily Load (TMDL) for stream segment DA04 (Macoupin Creek) ultimately
receiving flows from Outfall 001 was completed and approved by USEPA on September 27,
2006 for total suspended solids, total phosphorus, manganese and fecal coliform. Stream
segment DAZL (Spanish Needle Creek) ultimately receiving flows from Outfalls 002, 003, 004,
005 and 007 discharges is not on the 2012 303(d) list of impaired waters.
After the hearing in 2011 and the public comments were reviewed, the Applicant contacted the
Illinois EPA and presented plans for underground disposal of fine coal refuse (slurry). The
Applicant also presented to the Illinois EPA a revised reclamation (abandonment) plan for
Refuse Disposal Area No. 5 and 6 and modification of associated groundwater monitoring
plan. This plan was proposed to help in addressing the local area groundwater contamination.
Because of these proposed plans, the Illinois EPA decided to postpone issuance of the
NPDES permit in 2011.
The Illinois EPA decided to modify the NPDES Permit and include the plan for underground
disposal of fine coal and the revised reclamation plans. The modified NPDES Permit was
again posted for public notice and a public hearing was held on March 11, 2014.
The updated information contained in the current permit from the 2011 permit includes the
underground disposal of fine coal refuse, groundwater extraction trenches which are part of the
Corrective Action Plan (CAP), revisions and details regarding the process water handling and
management plan, and water process system. The current permit allows the Illinois EPA to
clarify in the permit that a liner meeting the design permeability of no greater than 10 to the
minus seventh centimeters per second would be required in Slurry Cell Number 5, regardless
of whether or not wastewater came into contact with coal refuse.
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Responses to Comments, Questions and Concerns
Comments, Questions and Concerns in regular text
Illinois EPA responses in bold text
NPDES Permit
1.
Is there a 404 permit for this project 2?
Yes, the U.S. Army Corps of Engineers issued a Nationwide 404 permit #12 (NMP12)
authorizing the installation of pipelines for slurry disposal into mined voids and
recovery of decant water on October 25, 2011.
2.
Why does the permit allow for additional water to be pumped to Refuse Disposal Area 6 from
the south holding pond slurry injection return water?
The pumpage of water from the South Holding Pond into RDA (Refuse Disposal Area)
No. 6 was proposed under IEPA Log No. 4221-94. The pumping of this water into RDA
No. 6 is to provide and introduce additional makeup water as necessary into the coal
preparation/washing process. This is one of several water transfer options that the
Applicant has requested and approved to allow sufficient flexibility to insure against
running short of water for the preparation plant operation during the dry summer
months.
Also, please refer to the response to Item No. 43 below.
3.
What waste streams are allowed to empty into Smith Reservoir?
There is an emergency overflow from RDA Number 5 that empties into Smith Reservoir
(Lake). Refer to the attached Water Flow Balance Diagrams contained in Log No. 317715 in the Illinois EPA files and are available for review under the Freedom of Information
Act.
4.
Are there withdrawals from the Smith Reservoir being permitted?
There is a return pump for makeup water from Smith Reservoir (Lake) that is approved.
Refer to the attached Water Flow Balance Diagram. Smith Reservoir (Lake) is on the
mine property, and a treatment works for the mine. Since the treatment works is not a
water of the State, no permit is necessary to withdraw water from the reservoir.
5.
Are water withdrawals allowed from adjacent streams for use at Shay 1 Mine, including from
Spanish Needle Creek, Macoupin Creek or tributaries to either?
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Yes. Water withdraw is permitted from Spanish Needle Creek and Macoupin Creek, as
proposed in the construction of a pumping station under Log No. 5143-93 (IPR No. 45).
Also, please refer to the responses to Item Numbers 33, 34, 39, 40 and 43.
6.
Has the Mine Pollution Control NPDES permit section staff, the Illinois EPA Groundwater staff
and staff from the Site Remediation Program met at the same time to discuss Shay No 1
Mine? Have these three sections also met with Foresight Energy, Macoupin Energy and
MaRyan Mining together?
Yes, there have been numerous meetings, discussions and conference calls between
the Mine Program, Illinois EPA Groundwater Section and the Bureau of Land, Site
Remediation Program (SRP). Many of these meetings and/or discussions included
personnel from Foresight Energy, Macoupin Energy and/or MaRyan Mining.
7.
Regarding the management of onsite ponds such as recirculating ponds, holding ponds and
sedimentation ponds, are fines ever removed, and if so, how often?
The frequency of sediment being removed from the basins depends on the condition
(vegetative cover as opposed to exposed soils) and size of the watershed. The need for
sediments to be removed from basins is determined by visual observations, discharge
water quality (a trend toward deteriorating water quality may be indicative of excessive
sediment accumulation which reduces the stormwater treatment volume) and possibly
measurements of sediment accumulation.
8.
Where would the removed or dredged material be placed?
If the removed or dredge material contains contaminants, such as coal or coal waste, it
would be placed in the refuse disposal area. If the material is determined to be a clean
sediment material, it can be potentially used as a top soil substitute material. However,
IDNR/OMM would make the determination as to whether the material is acceptable to be
used for reclamation as subsoil or as a top soil substitute material.
9.
On this watershed map (E-4), directly east, slightly north of RDA 6 there is a continuation of
the public water supply back up for Lake Carlinville. Is the Illinois EPA concerned if there was
a breach or inundation type spill at RDA 6 that this area could be contaminated?
The RDA No. 6 facility was designed and engineered to prevent a breach or spill, even in
the event of seismic activity (earthquake). Therefore, the Illinois EPA has no reason to
expect such a breach or spill might occur. However, in the remote event that such a
spill would occur, emergency response plans have been developed by the mine to
mitigate any breach or inundation.
10. Are there any wetlands or, prairie pothole potential wetlands that Illinois EPA hasn’t identified
in the acreage being added under this NPDES?
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The Illinois EPA contacted the U.S. Army Corps of Engineers to determine if they were
aware of any jurisdictional impacts to Waters of the U.S. The Corps of Engineers
indicated that they did issue a Nationwide 404 permit on July 21, 1988 for impacts to
Waters of the U.S. from construction of RDA #6. The Illinois EPA and Corps of
Engineers are not aware of any other impacts to Waters of the U.S.
11. Considering the fact that there does appear to be some changes in our climate, does the
Illinois EPA check to assure if the 24 rainfall event figures are accurate?
Rainfall values or amounts used for design purposes are from published data
developed from historical rainfall records. These design storm precipitation events
include and account for historical climate changes. The rainfall data presented in this
application were obtained from published data and are the accepted standard for
engineering design and practices.
12. Why are the classifications for Outfall 003 and Outfall 004 being changed?
Outfalls are reclassified based on the condition of the watershed tributary to the basins.
The watersheds tributary to Outfalls 003 and 004 consist of the outslopes of older
refuse disposal areas. These slopes have been covered with soil and have been
revegetated. The condition and characteristics of the watersheds to these basins and
outfalls qualify the outfalls for reclassification from alkaline Outfall 003 to stormwater
discharge and reclamation Outfall 004 to stormwater discharge.
13. Does the Illinois EPA have any concerns regarding the RDA 6 slopes?
The vegetation and/or revegetation of refuse disposal area slopes are reclamation
activities and are governed by IDNR/OMM regulations. According to the information
provided by IDNR/OMM, no subsoil or topsoil has been placed on the slopes of RDA 6 at
this time. Therefore, RDA 6 has not yet been vegetated. Appropriate soil cover and
vegetation will be established per the approved reclamation plan in IDNR/OMM Permit
No. 209 for RDA No. 6 once the RDA is capped.
14. Is there a limit on the volume of water transferred from RDA 5 to Smith Lake?
The maximum flowrate of water that is transferred or pumped from RDA5 to Smith Lake
is limited by the pumping rate of the installed pump. During the peak years of the CAP
(Corrective Action Plan) on RDA 5, pumping flows will range from 49.0 to 92.9 GPM
(Gallons Per Minute) during the first three (3) years to 16.0 GPM by year nine (9) when
the cover on RDA 5 is completed. However, as per the original request and as specified
in the NPDES permit, the volume of water transferred from RDA No. 5 to Smith Lake
shall be limited to prevent a discharge from Smith Reservoir (Lake).
15. The permit on Page 19 states that the disposal of fine coal refuse underground is authorized.
Downgradient recovery wells are described. Will these wells need to operate into the indefinite
future to capture decant water and protect groundwater resources from contamination?
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A facility or operation approved for underground slurry disposal is required to install
and operate downgradient wells that will withdraw a volume of water approximately
equal to the volume of water that is being placed underground during the disposal
operation. This prevents the buildup of hydraulic head in the underground mine voids
that would potentially force the slurry decant water into the surrounding groundwater.
These downgradient wells will no longer be operated once the slurry disposal point is
relocated or if the underground slurry disposal operation ceases because there will no
longer be a potential for the buildup of hydraulic head in the underground mine void.
16. Will there be any monitoring of pollutants in the water collected by the recovery wells?
The water from the down-gradient slurry disposal wells will be pumped to the surface
and maintained in the coal preparation or coal processing circuit. Therefore, since
there is no offsite discharge of this water, there are no monitoring requirements under
the NPDES permit for this slurry decant return water.
17. Will there be TCLP testing in regards to the NPDES permit at some point?
There are no Toxicity Characteristic Leaching Procedure (TCLP) monitoring
requirements included in the NPDES permit. TCLP analyses are required only when
coal combustion waste (CCW) is approved for disposal. At the Shay No. 1 Mine there is
no CCW approved for disposal; only coal combustion by-products (CCB’s) have been
approved by IDNR/OMM for utilization in the reclamation of the coal refuse disposal
areas. The coal combustion by-products being utilized in the reclamation of the RDA’s
at the Shay No. 1 Mine have been appropriately characterized utilizing the ASTM 398785 testing method.
18. Will there be a new slurry pond or a pool construction within this NPDES, and could this be an
incised impoundment or could that be changed into a new RDA?
This NPDES permit renewal does not authorize construction of any new slurry pond or
pool.
19. We are aware that there are plans for a very large long wall mine to be tied into this operating
plan on this specific NPDES permit in the future. Will the IEPA review this NPDES for potential
additional contamination if a larger facility does indeed happen?
In the event that surface storage of coal at this facility increases, additional refuse
disposal areas are proposed, coal production increases, etc., the sedimentation basins
receiving runoff from such activities or expansion areas would be evaluated as
“expanded discharges” under the anti-degradation regulations as well as evaluated for
adequate treatment capacities. These re-evaluations would require a modified NPDES
permit which would be subject to the public notice and comment requirements of the
Clean Water Act.
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20. How is the IEPA approving slurry injection at this facility when it only affords enough space for
less than 5 years of space, yet a whole other longwall mine is being planned to tie in, in 3
years?
The Illinois EPA has not received any such permit applications. IEPA will review any
such modification requests in accordance with applicable rules and regulations.
21. Why has the slurry pool level at the RDA not increased in the 5 years that Macoupin Energy
has owned the mine? Are you certain there have not been unpermitted releases?
During that initial five-year period, there is very little, if any, mining because they were
restoring the underground facilities back to safe operating conditions following the
extended period of being idle. Also, during this time of restoration or upgrading, there
was little or no coal being produced and cleaned that would have added to the slurry
disposal area.
Based on the oversight and inter-agency communication by IDNR/OMM and the Illinois
EPA, it is believed that there have been no “unauthorized” or “un-reported” discharges
from this facility or operation.
22. What has Illinois EPA done to evaluate potential risks and impacts from subsidence and/or
impounding wall failure (of RDAs) to area water resources? Has a risk assessment been
completed for the proposed trenching and the impact of that removing up to 140 ft. depth of
substrate near the toe of the impoundment may have on structural integrity and stability?
Subsidence and the risks associated with subsidence are outside the scope of the
Subtitle D: Mine Related Water Pollution regulations. These risks and impacts are
evaluated and addressed by IDNR/OMM. The RDA’s at this facility are designed in
accordance with MSHA (Mine Safety and Health Administration) regulations. These
designs were reviewed and approved by MSHA to insure the structures are stable
against failure under design conditions which includes potential seismic activity
(earthquakes).
The trenches that have been proposed to capture groundwater that has been impacted
by the RDAs will probably not exceed 30 feet in depth, but final designs will be
submitted for Illinois EPA review. It should also be clarified that the trenches will not
remain open and therefore subject to collapse. The trenches will be backfilled with
sand that will readily conduct water to a pipe that will be laid in on the bottom of the
trench. The pipes will lead to sumps where the water can be pumped out to the slurry
circuit.
23. What is the purpose of this permit? I would like further clarification in laymen’s language as to
the purpose of this permit. Is the purpose of the permit to approve the present methods of
cleaning the water before it’s discharged?
10
The basic purpose of this permit is to regulate the discharges from the site into waters
of the state or receiving streams to ensure that those discharges meet applicable
effluent limits or water quality standards.
24. On page 13 of the draft permit is a paragraph that discusses discharge 001, the inoperative
sanitary wastewater system. One sentence states that the system is inactive and shall not be
utilized until the requirements of condition no. 13 have been fulfilled. Is that sentence
supposed to refer to condition no. 17 rather than condition no. 13?
No, the reference to Condition No. 13 is correct. The reference on Page 13 of the draft
permit is to Condition No. 13 of Construction Authorization No. 8107-10 which can be
found on Page 16 of the draft Permit. This Condition indicates that the discharges from
Outfall 001 will be subject to the limitations of Special Condition No. 17 of the draft
Permit (Page 22) regarding residual chlorine or de-chlorination unless a disinfection
exemption is requested and obtained prior to discharge.
25. Why is the mine given a disinfection exemption for Outfall A02?
The facility applied for and was granted a disinfection exemption for Outfall A02 based
on the Illinois EPA’s determination that the recirculation pond is not a “protected
water”, i.e., a water body that supports swimming, for the purposes of 35 Ill. Adm. Code
302.209. Additionally, the Illinois EPA determined that the exemption would not result
in exceedance of the fecal coliform standard at any downstream Public and Food
Processing Water Supply intake.
26. Could you explain why Outfalls 002 and 005 are listed as acid mine drainage while Outfall 007
is listed as alkaline mine drainage?
Outfalls 002 and 005 receive runoff from active areas of the operation, including the
preparation plant and the active RDA 6. These active areas both have potentially acid
conditions. Outfall 007 receives water from areas of the facility that have been reclaimed
with alkaline-producing materials. Whether an outfall is classified as acid or alkaline is
based on the runoff that is tributary to the basins, not the discharge itself.
27. Is the water inside the RDAs considered to be stormwater?
The water within the RDA is mostly water used in the coal preparation and processing
circuit. Of course, these impoundments would collect and retain stormwater that falls
directly on the impoundment during precipitation events. Therefore, the water within
the RDA’s may be considered a combination of process water and stormwater.
28. The construction authorization states that the recirculation pond serves as the treatment pond
for the preparation plant and associated areas including the coal stockpiles. Why then is Smith
Lake being used as a treatment pond for runoff and pumpage from Outfalls 005 and 006?
11
Smith Reservoir (Lake) is not being used as a treatment pond for Outfalls 005 and 006.
It is used as treatment works for surface water runoff from the slopes of RDA 5; for
gravity-induced flows from the pool of RDA 5, wick drains, and collection ditches; and
water pumped from the pool of RDA 5.
29. Why does one of the log numbers allow water from RDA5 to be emptied into Smith Lake
without meeting permit limits and without requiring water quality standards in Smith Lake?
Water quality standards must be met in the waters of the state. Smith Reservoir is
exempt from the definition of waters of the state because it is considered to be
“treatment works.” The “waters” that IEPA and the Illinois Pollution Control Board
(“IPCB”) are charged with regulating are defined in Section 301.440 of Title 35 of the
Illinois Administrative Code as follows:
[A]ll accumulations of water, surface and underground, natural, and artificial, public and
private, or parts thereof, which are wholly or partially within, flow through, or border
upon the State of Illinois, except that sewers and treatment works are not included
except as specially mentioned; provided, that nothing herein contained shall authorize
the use of natural or otherwise protected waters as sewers or treatment works except
that in-stream aeration under Agency permit is allowable.
In 35 Ill. Adm. Code 301.415, “treatment works” is defined as follows:
[I]ndividually or collectively those constructions or devices (except sewers, and except
constructions or devices used for the pretreatment of wastewater prior to its
introduction into publicly owned or regulated treatment works) used for collecting,
pumping, treating, or disposing of wastewaters or for the recovery of byproducts from
such wastewater.
Smith Reservoir is a sediment control structure mandated by 35 Ill. Adm. Code 406.108
(mine wastewater “shall be passed through a sedimentation pond or a series of
sedimentation ponds before leaving the facility”). IPCB rules allow, under certain
circumstances, the construction of these structures “in stream.” See 35 Ill. Admin Code
Section 405.105(d).
IEPA and many other regulatory bodies widely consider
sedimentation control structures, such as Smith Reservoir, to be the best and most
practicable treatment technology to control suspended solids from mining discharges.
Given all of the above, the IPCB has long held that coal mine sediment control
structures are “treatment works” and therefore not waters of the state. In 1980, the
IPCB addressed this issue precisely, and has held fast to that ruling ever since. In
Amax Coal Co. v. IEPA, PCB 80-63 (December 19, 1980), the IPCB held as follows:
In requiring sedimentation ponds in Rule 608 of new Chapter 4, the Board did not
expressly intend that they be limited to perched ponds or other facilities which are not
formed by damming a stream or ravine. These particular sedimentation ponds in
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intermittent streams fall within the exception for treatment works in Rule 104 of Chapter
3 and are not “waters of the State.” Id. at p. 10.
Smith Reservoir is such a sedimentation control structure. It is a manmade reservoir,
and its permitted use, for many, many years has been to collect wastewater from the
facilities at the Shay No. 1 mine, to treat them by allowing the settlement of sediment,
and to then discharge compliant water. Outfall 007 is at the decant of Smith Reservoir,
and it denotes the point at which the treatment works discharge into waters of the state.
Outfall 007 contains effluent limits sufficient to protect waters of the state.
Smith Reservoir is completely contained within land now owned by Macoupin Energy,
and has been on private lands owned by mining companies that preceded Macoupin
Energy’s ownership. It is also wholly within Illinois DNR mining permit # 056, and has
been since permitting requirements came into existence. It is not public or recreational.
Accordingly, IEPA has concluded based on regulations and IPCB rulings that Smith
Reservoir has and has always been treatment works.
Because Smith Reservoir is not a water of the state, discharges into Smith Reservoir
are not required to be reviewed for compliance with water quality standards. Instead,
water quality standards are maintained through the use of Outfall 007, at the decant.
Notwithstanding this precept, IEPA has imposed limitations on water being transferred
by pumpage to Smith Reservoir. Pumped water cannot be transferred in such a volume
as to cause a discharge from Smith Reservoir, and any such pumpage must meet
effluent standards applied to Outfall 007 before it enters Smith Reservoir.
30. Has the chemical characterization been done so that Illinois EPA knows what is coming from
RDA5? Any discharge coming from RDA5 into Smith Lake will impact Outfall 007, therefore
analysis of RDA5 discharge should be required in order to ensure that discharge from Outfall
007 will meet water quality standards for both quality and quantity.
The applicant conducts their own chemical monitoring of RDA5 for pH, iron,
manganese, sulfate, and chloride and has previously submitted this data to the IEPA
along with chemical data for RDA6, Smith Lake, the south holding pond, the
recirculation pond, and Outfalls 002, 005, and 007. Effluent limits for Outfall 007 do take
into consideration the pollutants that are present in RDA5 and could potentially be
present at Outfall 007. Based on the data received by the IEPA, the water quality of
RDA5 would not lead to exceedances of effluent limits imposed at Outfall 007.
31. 35 Ill. Adm. Code Section 309.106 provides for the Illinois EPA to conduct a site visit or obtain
additional information in order to evaluate an NPDES permit application. We request that the
Illinois EPA use their authority for such a request and deny issuance of this final permit until
the applicant is able to demonstrate and ensure compliance with applicable permits, rules and
regulations for the duration of the permit’s life.
13
The Illinois EPA has requested additional information and/or clarification regarding
several issues during the permit review process. This includes additional information
related to the underground slurry disposal application, anti-degradation assessment,
etc.. Information provided by the Applicant during the permit review process has
demonstrated that the facility can meet the applicable permit limits which are the basis
for the draft NPDES permit that was public noticed.
32. On page 13 of the draft permit, it discusses the transfer of water from RDA5 to Smith Lake. It
says that this pumping of water is for maintaining a stable water level in Smith Lake. Why are
you trying to maintain a stable water level in Smith Lake?
Raw make-up water (clean) water is collected from Smith Lake and placed in facilities
water tower from where it is directed for underground mine use for dust suppression,
fire protection and replenishment of evaporative losses. Raw water from the tower
averages 144 GPM. Approximately 15 GPM is captured in the underground sumps and
returned to the Recirculation Pond while the remaining 129-130 GPM is captured in the
coal or lost in the mine.
In the event that the water level in Smith Lake becomes too low, a sufficient volume of
supplemental water may not be available for operation of the preparation plant and
control of dust in the underground mining operations.
Maintaining a stable water level in Smith Reservoir (Lake) helps in providing an
adequate volume of supplemental water to support the preparation plant and
underground mining operations.
33. Why is 1000-1500 gallons per minute pumped from Macoupin Creek to Smith Lake?
Water withdrawal from Macoupin Creek being directed to Smith Reservoir (Lake)
supports a stable water level in Smith Reservoir (Lake) as discussed in the response to
Item No. 32 above. As also indicated above, the water in Smith Reservoir (Lake) may be
utilized for make-up water for the preparation plant coal washing process as well as for
dust control in the underground mining operations.
34. Log 5143-93 describes pumping out of Spanish Needle Creek.
pumping station on Spanish Needle Creek? Why is this needed?
What is the role of the
The withdrawal of water from Spanish Needle Creek is basically for the same purpose
as the withdrawal of water from Macoupin Creek as discussed in the response to
Question No. 32 above. This additional water source is used in the event that an
insufficient volume of water is available from Macoupin Creek.
35. Log 2186 and Log 116-97 describe transfers of water from RDA5 and the Recirculation Pond
to RDA6 and then from RDA6 to the South Holding Pond. Why is water needed at RDA6 at
the same time that water needs to be removed from RDA6? Does Illinois EPA have a
characterization of the water proposed to be transferred from RDA5 to RDA6? Does Illinois
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EPA have a characterization of the water proposed to be transferred from the Recirculation
Pond to RDA6? Does Illinois EPA have a characterization of the water proposed to be
transferred from RDA6 to the South Holding Pond?
Illinois EPA requires that the effluent proposed to be discharged from each outfall be
properly characterized, which includes representative sampling and development
effluent limits for each outfall. Water that is managed within the facility is not required
to be characterized.
The RDA No. 6 will provide settling for suspended solids from water pumped from other
impoundments as well as settlement of coal fines in coal refuse (slurry) from the coal
preparation plant. South Holding Pond, Recirculation Pond, and RDA 5 perform similar
functions. So, water could be placed into RDA6 to allow sufficient holding time for
settlement of suspended constituents. Then, once adequately clarified, it can be moved
to South Holding Pond and from there it is ready to be discharged. Additionally, water
from these ponds can be transferred to the Recirculation Pond as needed to provide
sufficient water for use in the processing plant and/or underground mine works.
36. Will the water that is in RDA5 be spilling over the spillway or pumped from the interior of RDA5
into Smith Lake? Is it precipitation driven discharge or will it be pumped? (T27, Line 10) In the
permit material it is described both ways.
Water can enter Smith Reservoir (Lake) from RDA No. 5 by precipitation event gravity
flows, or it can be transferred (pumped) into this lake under certain conditions as set
forth in the permit.
37. Why isn’t Outfall 007 which has discharge limits included in the permit for the water to be
pumped from RDA5 to Smith Lake?
Please refer to the response to Item No. 29 above.
38. How is the spillway at RDA5 considered to be an “internal structure” with “no NPDES
impacts?”
39. On page 13 of the proposed permit there is mention of the installation of a pumping station on
Spanish Needle Creek. Is it typical that a mine has a pumping station on a creek? Is the
pumping regulated to protect downstream flow conditions? Where do I find the conditions?
Pumping stations are often constructed on streams to provide an adequate source of
make-up water for the coal processing activities. IDNR, Office of Water Resources, is
the regulatory authority responsible for ensuring proper management of water
resources.
15
40. Is it permissible to pump water out of a stream such as Spanish Needle Creek as a method to
dilute pollutants in effluent from a site? This is expressly prohibited by 35 Ill. Adm. Code
Section 406.104.
The pumping of water from Spanish Needle Creek is not for dilution purposes. The
approval to pump water from Spanish Needle Creek is to provide additional make-up
water for the coal preparation process during dry weather conditions.
For clarification purposes, it is noted that Section 406.104 provides, in part, that the
dilution of an effluent from a treatment works is not acceptable as a method of
treatment in order to meet the effluent standards. However, please note that 35 Ill. Adm.
Code Section 302.102 of the Board regulations allows utilization of dilution of a
discharge to meet a water quality standard. In the case of the Shay No. 1 Mine, neither
of these situations are applicable.
41. Would the Illinois EPA ever allow pumping of water out of a water body to dilute pollutants so
that they could meet water quality standards upon discharge?
While the regulations prohibit dilution to meet an effluent standard (35 Ill. Adm. Code
304.102; 406.104), there is no prohibition for the dilution of effluents to meet water
quality standards. Please see 35 Ill. Adm. Code Section 302.102 for more details.
42. Has Illinois EPA reconsidered allowing all of the transfers of water from different basins?
All of the water transfers approved over the past several years have been considered
and evaluated under the anti-degradation assessment that was performed for this
Permit, as well as have been considered for the classifications of outfalls. Therefore,
there is no reason for reconsideration of water transfer approvals.
43. Why are there so many transfers of water among: RDA6 with a flocculation station; RDA5,
Smith Lake, Recirculation Pond with pump to remove sediment; South Holding Pond with a
pump station, a 12 inch siphon line at Outfall 005; and a Spanish Needle Creek pumping
station? Specifically provide information on pollutant concentrations or volumes of water being
transferred.
The Illinois EPA asked the Applicant to provide a complete summary of waters
transferred at this mine. Information provided by the Applicant is provided below. The
only time water is pumped onto the property from Spanish Needle Creed or Macoupin
Creek are during drought conditions when there is not enough water to operate the
plant and/or underground operations. According to the Applicant, the only time water is
pumped from holding pond to another is to keep all ponds full during spring rains so
that there is plenty of water on site going into the summer and they do not have to
pump water from off site.
1. The only pump in RDA #6 is used to pump water to the Recirculation Pond
to be used in the Plant. The flocculation station has nothing to do with
16
water transfer to any location. Flocculent was only used to aid in settling
out solids in the slurry so the water could be reused at the plant.
2. No water is pumped out of RDA #5, it has a decant and an emergency
spillway which both discharge into Smith Lake.
3. Smith Lake pumps water into the water tower which supplies water to the
underground operations, all surface facilities for fire suppression and wash
down water. The tower has a discharge valve to transfer water into the
Recirculation Pond which is only used when there is insufficient water in
RDA #6 to keep the water level in the Recirculation Pond at the needed
height to operate the plant.
4. The Recirculation Pond is a finish pond used to supply water to the plant.
Its primary source of water is from RDA #6. If there is not enough water in
RDA #6 then water is pumped from Smith Lake. Water from the
Recirculation Pond also supplies a water sump outlet to fill the water truck
that is used as dust suppression on all the mines roadways. During the
spring, the mine can also pump water back into RDA #6 to make sure the
mine can retain as much water in the spring as possible to have enough
water to make it through a dry summer. There is no pump in the
Recirculation Pond used to remove sediment.
5. The pump station in the south holding pond is used to pump water from the
spring rains into RDA #6 to be used during the dry summer weather. The
12 inch siphon line is used to discharge water at 005 discharge point. It
has been used to drain the South holding pond when settled solids had to
be removed to maintain its required holding capacity.
6. The Spanish Needle Creek pumping station is only used during summer
droughts when water is needed to operate the mine and all other water
supplies are dry or near dry.
7. Macoupin mine also has a permit to pump water from Macoupin Creek
when all water supplies are too low to operate the mine. The water is
pumped into Smith Lake where it can then be pumped to the Recirculation
Pond to be used to operate the plant as detailed above.
The above information was provided to the Illinois EPA in a document entitled,
“Application for the Modification of National Pollutant Discharge Elimination
System (NPDES) Permit [IL0056022]” dated May 2013 and submitted with the
permit application. Water test results were also included in the application and
the quarterly reports.
17
44. Notification of transfer and analysis results shall be provided to the Illinois EPA within 15 days
of transfer. Who receives and reviews this information? How is it enforced? Is there public
process to review these materials?
As indicated in Special Condition No. 3 of the permit, the analysis results will be
submitted to the Illinois EPA’s Compliance Assurance Section with a copy provided to
the Mine Pollution Control Program. This information will be reviewed by Illinois EPA
personnel (both Compliance Assurance Section and Mine Program) to determine
compliance with permit requirements and limitations. There is no standard or routine
process for public review of these sample analyses, however, the sample analysis
results would be available for public review under the Freedom of Information Act
(FOIA).
45. What are the chemical constituents of the coagulate 220 and 222?
The coagulants are added to aid in precipitating out suspended solids and metals so
that effluent meets effluent permit limits and water quality standards. The Applicant
submitted MSDS (Material Safety Data Sheet) for these products in the approval
process. MSDS sheets for these products are on file with the Illinois EPA and are
available for review under the Freedom of Information Act (FOIA).
46. Why do they need to add an aluminum based chemical to the runoff?
Stormwater runoff inherently has high total suspended solids. Products such as
Coagulant 200 and 222 are often utilized by mines (and other NPDES-regulated
dischargers) to settle out suspended solids prior to discharge in order to meet NPDES
permit limits.
47. Has RDA6 ever spilled over the top?
No, the Illinois EPA is not aware of any overflows incident(s) occurring from RDA 6.
48. How structurally sound is RDA6? Has there been leaching and erosion of RDA6?
The design of RDA No. 6 was evaluated and approved by the Mine Safety and Health
Administration (MSHA), IDNR/OMM and the IEPA. The initial application for this
structure included designs for both static and seismic (earthquake) stability. Therefore,
RDA No. 6 was designed to remain stable even under seismic or earthquake conditions.
The MSHA approval of this structure also requires weekly inspections of the structure
to ensure there are no instability issues and to inspect for excessive erosion which
would be addressed during normal or routine maintenance activities.
The Illinois EPA believes that leaching is occurring through the foundation of the
structure into the local groundwater. Therefore, the IEPA has required the development
of a CAP for RDA No. 6.
18
49. Why is the Illinois EPA drafting a permit and proposing continued mining, coal washing and
disposal onsite if you know that there are problems that could impact public health, aquatic life
and the designated uses that are required to be protected?
This permit was prepared to ensure that all new or proposed activities will be performed
in a manner protective of public health, aquatic life, and designated uses of general use
waters. The permit has also been prepared and drafted to include conditions and
requirements to address and/or correct environmental issues or problems that are a
result of previous mining activities.
Water Quality Standards/Antidegradation Assessment
50. Will there be any additional pollutant loading for parameters that are already exceeding either
groundwater or surface water standards at the site?
The draft NDPES permit does not authorize additional pollutant loadings from outfalls
permitted at this site. Pollutant loadings are expected to decrease compared to
previously permitted conditions, as summarized in the Applicant’s NPDES Permit
Application dated November, 2013. Additionally, the modified NPDES permit would
include permit limits that are water quality standard based, which would be more
stringent than limits contained in the previous NPDES permit.
51. Did Illinois EPA staff compare volumes of waste water, change in concentrations of pollutants
in waste streams, or change in loading of pollutants in waste water? Were these comparisons
done in total to the receiving body, or per individual outfall?
Illinois EPA assessed the volume of flow and water chemistry of each outfall and also
took into consideration the flow and water quality of the receiving water in order to
determine permit limitations for each individual outfall. Changes in volumes and
concentrations of pollutants at each outfall were also considered. Also, please refer to
the response to Item Nos. 65 and 72 below.
52. Can you please tell us the extent of surface water sampling that has been conducted at Smith
Reservoir and what the results have been?
During review of the modified permit, the Illinois EPA received data that included an
analysis of surface water samples collected in Smith Lake on February 10 th, May 10th,
and June 6th, 2010. The water quality of Smith Lake was found to be similar to that of
effluent from Outfall 007 (Averaged results = pH 8.2, 0.1 mg/L total iron, 0.07 mg/L
manganese, 248 mg/L sulfate, and 194 mg/L chloride). According to the Applicant, this
is the extent of sampling that has been conducted in Smith Lake.
53. Special Condition 17 is a two-year compliance schedule for Outfall 007 to meet chloride water
quality standards of 500 milligrams per year. What is the basis for the two-year compliance
schedule, and what treatment methods for chloride are being considered?
19
At this time, the mine believes that compliance with the 500 mg/L chloride limit at
Outfall 007 can be attained without the need for relocation of the discharge structure.
Therefore, Special Condition 17 has been removed from the NPDES permit.
54. How does Special Condition 17 fit with Special Condition 16, which says that discharges of
chloride up to 1000 mg/L will be allowed from Outfall 007?
At this time the mine believes that compliance with the 500 mg/L chloride limit at Outfall
007 can be attained without the need for relocation of the discharge structure.
Therefore, Special Condition 17 has been removed from the NPDES permit.
55. Special condition 17 gives the option of moving Outfall 007 to Spanish Needle Creek. Will
that, if they do that, require an antidegradation analysis and would the public have an
opportunity to comment?
At this time, the mine believes that compliance with the 500 mg/L chloride limit at
Outfall 007 can be attained without the need for relocation of the discharge structure. A
check of the facility’s last five years of discharge monitoring reports (November 2009 –
November 2014) for Outfall 007 shows that effluent has been consistently attaining the
chloride water quality standard (maximum result was 263 mg/L chloride). Given that the
mine believes compliance with the 500 mg/L chloride limit can be attained, Special
Condition 17 has been removed from the permit. Also, please refer to the response to
Item No. 66 below.
56. Has Illinois EPA evaluated cumulative impacts of allowing chloride discharges of up 1000 mg/L
at three outfalls, Special Condition 16 to Spanish Needle Creek and on whether the water will
exceed the State's water quality standard of 500 milligrams per liter?
The Illinois EPA has evaluated the cumulative impacts of allowing chloride discharges
up to 1,000 mg/L at the specified outfalls.
57. What is the basis for the two-year compliance schedule to meet the proper total residual
chlorine levels in Special Condition 18?
The residual chlorine of that special condition, is related to a sanitary waste water
discharge that is currently inactive, and that special condition will take effect if and
when the mine wants to reactivate that sanitary waste water discharge.
58. Are the selenium detection levels within USEPA’s water quality standards?
The detection limit for selenium specified in Special Condition 20 is 0.005 mg/L, which
is equivalent to the chronic USEPA National Recommended Water Quality Criterion for
this substance.
20
59. Illinois EPA has not demonstrated that the proposed discharges will not cause or contribute to
the violation of water quality standards in tributaries and/or mainstem reaches of Spanish
Needle Creek and Macoupin Creek. The Illinois EPA must include limitations in the permit
necessary to achieve water quality standards. Such limitations must control all pollutants
which will cause, have the reasonable potential to cause, or contribute to an excursion above
any state water quality standard. 40 CFR 122.44 (d) (1). Despite this requirement, no
reasonable potential analysis has been performed on the proposed pollutant loadings.
The Illinois EPA has included permit limitations that would require attainment of water
quality standards either at the outfall or outside of an allowed mixing area as authorized
by 35 Ill. Adm. Code 302.102. Regulation of the discharges as proposed by the draft
permit would not lead to a violation of water quality standards in Spanish Needle Creek
or Macoupin Creek. A formal reasonable potential analysis of pollutants was not
conducted for the renewed permit because chloride, iron, manganese, and sulfate
permit limits (along with mercury monitoring) are always required for acid mine
discharges and alkaline mine discharges with coal refuse or coal combustion waste
disposal areas, regardless of the concentration that is actually present.
By
incorporating limits in the mine permit, the Illinois EPA ensures that best management
practices are always carried out by the regulated facility. Given that the renewed permit
does not allow increases in pollutant loading compared to previously permitted
conditions, no additional permit limitations were necessary.
60. The Illinois EPA has failed to fully identify and quantify proposed pollutant load increases and
the potential impacts of those load increases on the affected waters and share the findings
with the public. The modifications stated in the Illinois EPA factsheet leave out major
modifications described as “water management and transfer” that can be found in the
construction authorization dated August 23, 2010 (See p. 12 of draft NPDES permit). It
appears that several transfers of water between RDA-5, RDA-6, South Pond, Spanish Needle
Creek, Smith Reservoir and the Recirculation Pond are planned.
The draft NDPES permit does not authorize additional pollutant loadings from outfalls
permitted at this site. Pollutant loadings are expected to decrease compared to
previously permitted conditions, as summarized in the Applicant’s NPDES Permit
Application dated November, 2013. Additionally, the modified NPDES permit would
include permit limits that are water quality standard based, which would be more
stringent than limits contained in the previous NPDES permit. Water management and
transfers of water proposed on site were considered. When reviewing water chemistry
data used in determining permit limitations for Outfalls 002, 005, and 007, the IEPA also
received and reviewed data for RDA5, RDA6, the south holding pond, Smith Lake, and
the recirculation pond. The transfers of water on site have occurred under previous
permits and the Illinois EPA has acknowledged this in the past and present permits and
has set permit limitations at each outfall with this in mind.
61. The Illinois EPA has failed to demonstrate existing uses will be fully protected in accordance
with 35 Ill. Adm. Code 302.105. We specifically object to Illinois EPA’s failure to require
Macoupin Energy, L.L.C. to characterize conditions and existing uses for bodies of water
21
receiving mine and stormwater discharges from Outfalls 002, 003, 004, 005, and 007 in
violation of Illinois antidegradation regulations. The Illinois EPA Water Quality Standards
Section has stated numerous times that the Illinois EPA does not require any kind of
assessment of headwater-type streams, assuming they have very little aquatic life potential.
The importance of headwater streams is recognized by the scientific community. While
headwater-type streams may require different assessment methods, many do indeed have
important existing aquatic life uses that cannot be dismissed categorically as insignificant.
The renewed NPDES permit for this facility was not subject to an antidegradation
assessment given that there are no increases in pollutant loading compared to
previously permitted conditions. Subsequently, a formal characterization of the
existing uses and the physical, biological, and chemical conditions of the receiving
water was not required. Nonetheless, the Illinois EPA conducted a facility related
stream survey of Spanish Needle Creek on September 28, 2010 which consisted of a
physical, chemical, and biological characterization of this stream upstream,
downstream, and adjacent to the mine site. Spanish Needle Creek possessed good
aquatic life conditions and habitat, and chemical parameters were found to be attaining
General Use water quality standards at each sampling location.
62. Alternatives that could minimize increases in pollutant loadings (sulfate, chloride, iron,
manganese, etc.) have not been fully explored. The proposed mining facility has failed to
satisfy antidegradation regulations. The applicant has not considered alternatives to the use of
sedimentation ponds for treating runoff from raw and clean coal storage areas, coal refuse
storage area and discharges from the refuse disposal areas. Alternatives to sedimentation
exist that could facilitate the avoidance or minimization of increased discharges of sulfates,
chlorides, manganese, iron, mercury and suspended solids. In practice, sedimentation ponds
only address dissolved pollutants like sulfates and chlorides by holding them until they can be
discharged during a rain event when they can take advantage of the dilution. Sedimentation
ponds are clearly not effective at the Shay No. 1 site, as surface waters are being impacted by
discharges from the sedimentation basins. We request alternatives be evaluated to
“assure…all technically feasible and economically reasonable pollutant loading [be]
incorporated into the proposed activity.”
assessment and a subsequent assessment of alternatives given that there are no
increases in pollutant loading compared to previously permitted conditions.
63. Special Conditions 16 and 17 address chloride discharges at 002 and 005 to Spanish Needle
Creek and through 007 to the unnamed tributary to Spanish Needle Creek. Special Condition
16 allows concentrations up to 1000 mg/L to be discharged during rainfall events, granting
mixing zones downstream of each of these outfalls. Special Condition 17 establishes a
compliance schedule for Outfall 007. It is not clear from the permit materials what efforts
Macoupin Energy has undertaken to comply with the chloride water quality standard of 500
mg/L.
22
Other than utilizing best management practices on site, including the management and
transfers of water on site, it is unknown what other efforts the Applicant has undertaken
to comply with the more stringent chloride limits. At this time, the mine believes that
compliance with the 500 mg/L chloride limit at Outfall 007 can be attained without the
need for relocation of the discharge structure. A check of the facility’s last five years of
discharge monitoring reports (November 2009 – November 2014) for Outfall 007 shows
that effluent has been consistently attaining the chloride water quality standard
(maximum result was 263 mg/L chloride). Given that the mine believes compliance with
the 500 mg/L chloride limit can be attained, Special Condition 17 has been removed
from the permit. Also, please refer to the response in Item No. 66 below.
64. Further, 35 Ill. Adm. Code 302.102(b)(4) prohibits mixing in waters “containing mussel beds,
endangered species habitat, fish spawning area, areas of important aquatic life, or any other
natural features vital to the well-being of aquatic life in such a manner that the maintenance of
aquatic life in the body of water as a whole would be adversely affected”. What surveys have
been conducted to confirm these protected natural resources do not exist? Finally, according
to Section 302.102(b)(9), “no mixing is allowed where the water quality standards for the
constituent in question is already violated in the receiving water.” Please confirm this to be the
case.
The Illinois EPA conducted a facility related stream survey of Spanish Needle Creek on
September 28, 2010 which consisted of a physical, chemical, and biological
characterization of this stream upstream, downstream, and adjacent to the mine site.
Spanish Needle Creek possessed good aquatic life conditions and habitat. However, no
mussel beds, critical areas for endangered species, fish spawning, areas of importance
for aquatic life, or any other natural features were present to prohibit the Illinois EPA
from granting mixing for chloride during precipitation-driven discharge events. All
chemical parameters that were assessed, including chloride, were found to be attaining
General Use water quality standards at each sampling location. Based on this survey
and the known water quality of the stream and each outfall, the IEPA determined that
chloride mixing at each outfall would not adversely affect the maintenance of aquatic
life and would result in attainment of the chloride water quality standard outside the
areas of allowed mixing.
65. Explain the calculation for chloride and sulfate limits for Outfalls 002, 005, and 007?
The facility has had a history of high chloride and currently has a limit of 1,000 mg/L for
each outfall, therefore allowed mixing is required in order to meet the chloride water
quality standard of 500 mg/L downstream of Outfall 002 and 005. Because Outfall 007
does not currently discharge directly to Spanish Needle Creek and currently has no
available mixing, a chloride limit of 500 mg/L is necessary to assure that the chloride
water quality standard is maintained in the unnamed stream receiving the effluent. It
was initially thought that a compliance schedule would be appropriate to accommodate
the lower chloride limit at Outfall 007, with the expectation that the facility would
ultimately be required to construct a pipeline directly to Spanish Needle Creek to utilize
available dilution. However, at this time the mine believes that compliance with the 500
23
mg/L chloride limit at Outfall 007 can be attained without the need for relocation of the
discharge structure. Therefore, Special Condition 17 has been removed from the NPDES
permit. While a chloride limit of 500 mg/L is currently recommended for Outfall 007,
mixing calculations using an effluent concentration of 1,000 mg/L chloride are provided
below to demonstrate attainment of the 500 mg/L water quality standard should the
discharge point of Outfall 007 ever be relocated to Spanish Needle Creek to utilize
available dilution. The paragraph and table below summarize the available mixing for
each outfall and the chloride concentration that would exist downstream of each outfall.
Spanish Needle Creek is a zero 7Q10 flow stream and therefore is only available for
mixing with discharges that occur as a result of precipitation events. Because Spanish
Needle Creek is not a zero 7Q1.1 flow stream, only 25% of the water body is available for
mixing in order to meet the water quality standard of 500 mg/L. Given that the outfalls
only discharge in response to precipitation, it is assumed that runoff during storm
events is proportional between the receiving stream watershed and the mine pond
watersheds, therefore the ratio of receiving stream watershed to outfall watershed
equates to volume of flow (e.g., 9.56 miles 2 of watershed upstream of Outfall 005 and
0.58 miles2 of Outfall 005 watershed = 16.5:1 dilution ratio). Based on the watershed
size of each outfall and the Spanish Needle Creek watershed size existing upstream of
Outfall 005 (the most upstream outfall), the receiving water possesses adequate flow to
dilute effluent from each outfall down to 500 mg/L chloride outside of the mixing area.
The table below summarizes the chloride concentrations that would exist downstream
of each outfall. Outfall 005 calculations were based off the watershed size of Outfall
005, the watershed size of Spanish Needle Creek upstream of Outfall 005, chloride data
from Spanish Needle Creek collected upstream of Outfall 005, and a maximum chloride
effluent concentration of 1,000 mg/L from Outfall 005 during discharge events.
Calculation for Outfalls 002 and 007 were based off upstream watershed size, outfall
watershed size, calculated upstream chloride concentrations from mixing of upstream
effluent with Spanish Needle Creek, and a maximum chloride effluent concentration of
1,000 mg/L.
Outfall
005
002
007
Watershed
Watershed
Chloride
size
size of
upstream
upstream
outfall
of outfall
of outfall
2
(miles )
(mg/L)
(miles2)
0.58
0.19
0.95
9.56
10.14
10.33
38.9
93.9
110.6
24
Chloride
within
25%
mixing
area
(mg/L)
226.6
157
349.8
Chloride
downstream
of mixing
area (mg/L)
93.9
110.6
185.5
Sulfate limits were determined according to the water quality standards at 35 Ill. Adm.
Code 302.208(h) and were based on projected chloride and hardness concentrations
downstream of each outfall. Data collected from Spanish Needle Creek upstream of
Outfall 005 (the most upstream outfall) was used as the baseline hardness
concentration existing upstream of the mine. The calculated daily maximum sulfate
limits for each outfall are listed in the table below. Mixing allowance will not be needed
in order for the applicant to meet sulfate limits. To aid in future determination of sulfate
permit limits, continued monitoring for sulfate, chloride, and hardness should be
required in the receiving water downstream of each outfall.
Outfall
005
002
007
Downstream
Chloride
(mg/L)
93.9
110.6
185.5
Downstream
Hardness
(mg/L)
276.4
281.5
272.4
Sulfate
Limit (mg/L)
1730.5
1732.9
1629.4
66. Does Special Condition 16 call for the reduction of chloride concentrations in Outfall 007
effluent to 500 mg/L over the next two years? Why is the mine allowed to take two years
before they are in compliance with the chloride water standard?
The 24 month compliance schedule was developed to allow the mine adequate time
to first determine if the more stringent chloride limit could be met at the current
discharge location and, if not, would allow the mine adequate time to develop plans
and specifications for the pipeline, commence construction, and demonstrate
compliance with permit limitations at the new discharge location. However, a check
of the facility’s last five years of discharge monitoring reports (November 2009 –
November 2014) for Outfall 007 shows that effluent has been consistently attaining
the chloride water quality standard (maximum result was 263 mg/L chloride). At this
time, the mine believes that compliance with the 500 mg/L chloride limit at Outfall
007 can be attained without the need for relocation of the discharge structure.
Therefore, Special Condition 17 (the chloride compliance schedule) has been
removed from the NPDES permit, and Special Condition 16 has been modified to
reflect the requirement for Outfall 007 to meet the 500 mg/L chloride limit at all times.
67. In Special Condition 15, the last sentence says that a mixing zone for chloride has been
granted for each outfall. What is the size of that mixing zone for each outfall?
Each outfall is allotted 25% of the receiving water’s volume of flow existing upstream
of outfall. There is no defined area of mixing for each outfall, as mixing is only
allowed during precipitation events and all mixing zones are based on watershed
sizes of the outfalls and receiving water.
68. Does Illinois EPA calculate how far downstream it takes before the water quality standard is
achieved?
25
The standard should be met quickly given that only 25% of the stream flow is utilized
for mixing and under these circumstances the highest expected concentration within
the area of allowed mixing is 349.8 mg/L. The Illinois EPA expects that mixing will
occur quickly because of the turbulence in the receiving stream during precipitation
events.
69. Clarify what is meant by the term “designated uses” as it listed on page 2 of the fact sheet.
This term apparently differs from its meaning in stream classification.
“Designated Uses” as it appears on page 2 of the fact sheet was an error and should
have been replaced by “Potential Sources”, as the information below it was intended
to characterize the sources of each cause of impairment.
70. There is the need to explore alternatives that could minimize increases in pollutant loadings
(sulfate, chloride, iron, manganese, etc.). The state antidegradation rules at 35 Ill. Adm.
Code 302.105(c)(2) require that all reasonable measures be taken to avoid and minimize
pollutant loading.
The applicant has not considered alternatives to the use of
sedimentation ponds for treating runoff from raw and clean coal storage areas, coal RDAs
and discharges from the RDAs.
assessment and a subsequent assessment of alternatives given that there are no
increases in pollutant loading compared to previously permitted conditions.
71. Has the Illinois EPA conducted analysis to determine what is coming out of each of the
outfalls to assure that the water being released will meet water quality standards after all of
the transfers of water on this site?
The Illinois EPA is aware of the potential for transfers of water throughout the site.
The transfers of water on this site have occurred under previous permits and the
IEPA has acknowledged this in the past and present permits and has set permit
limitations at each outfall with this in mind. The IEPA reviewed water chemistry data
from Outfalls 002, 005, and 007, and also received and reviewed additional data for
RDA5, RDA6, the south holding pond, Smith Lake, and the recirculation pond in
order to determine permit limitations for each Outfall. The Illinois EPA determined
that chloride was the only parameter that may not meet water quality standards upon
discharge, but the chloride standard would be attained in the receiving water outside
of the area of allowed mixing.
Also, please refer to the response to Item No. 65 above.
72. Have the cumulative effects of Outfalls 002, 003, 004, 005, and 007 into the Spanish
Needle Creek been considered?
26
The Illinois EPA considered the water quality of Spanish Needle Creek and the
cumulative effects of each outfall when determining the appropriate permit
limitations for Outfalls 002, 005 and 007.
The Illinois EPA also performed a chemical, physical, and biological survey of
Spanish Needle Creek upstream, downstream, and adjacent to the mine site and
found that the mine was having no discernable effects on Spanish Needle Creek.
73. Are total suspended solids considered mine waste?
Total suspended solids is a pollutant regulated in NPDES mine permits to assure
that best management practices are being applied to retain and settle out suspended
solids prior to discharge. The regulation of this parameter in NDPES permitting
serves as a catchall for all suspended solids that could potentially be discharged at
a site, which may include mine waste (e.g., coal pile runoff) as well as stormwater
runoff from areas not containing coal or mine waste (e.g., reclaimed areas,
undisturbed areas, support areas).
74. Special Condition 12 requiring monitoring for total suspended solids, iron, pH, alkalinity,
acidity, sulfates and chlorides prior to pumping is not sufficient. The applicant and the
Illinois EPA must reestablish outfalls from each of the runoff and discharge streams at the
point of entry into the Smith Reservoir or an alternative waterbody and assign pollution
limits in the permit for each outfall to ensure water quality standards will be met in Smith
Reservoir.
Water quality standards are not required to be met in treatment works. Given that
Smith Lake is a treatment works for the mine, water quality standards are not
applicable within Smith Lake. However, water quality standards are applicable to the
overflow from Smith Lake (Outfall 007). Also, please see response to Items No. 4,
No. 28 and No. 29 above.
75. Why isn’t manganese required to be monitored given that there is a limit for manganese at
Outfall 007?
Special Condition 12 has been modified to include manganese as an additional
parameter to be measured prior to allowing water transfers from RDA 5 to Smith
Lake.
76. Does this site have PAHs and are there records that track PAH levels?
PAHs are lipophilic compounds, which means that they have a greater affinity to
bind to organic substances rather than water. Because of these properties, PAHs
bind to sediment and other organic materials and are not believed to be present in
groundwater or surface water discharges from this site. Given that no monitoring or
permit limits have been required for PAHs at this facility in the past, there are no
records regarding these parameters.
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77. Knowing there are exceedances of total dissolved solids, total suspended solids, iron,
manganese, sulfates, and chloride, what additional monitoring has been done to find out
what’s behind those indicated pollutants?
Prior to the first public hearing, Illinois EPA personnel reviewed the “Supplemental
Site Investigation Report; Shay No. 1 Coal Mine, Carlinville, Illinois” compiled by
Conestoga-Rovers & Associates from February 2011 (Ref. No. 054658(3)) and found
no evidence of surface water quality standard violations in Spanish Needle Creek.
78. Are effluent samples taken immediately outside of the outfall or are they taken from
different areas?
Effluent samples are collected at the end of the discharge pipe before the effluent
mixes with the receiving waters.
79. What month was the facility related stream survey conducted in?
The survey was conducted on September 28, 2010.
80. What method was used for collecting macroinvertebrates? Does that method include the time
that the survey should be conducted and the season
Methodology used in collecting macroinvertebrates is summarized in the Illinois EPA’s
November 16, 2011 draft document entitled Standard Operating Procedure for Methods
to Sample Wadeable Stream Macroinvertebrates to Detect Chemical Impacts from PointSource Discharges. The method specifies that facility related stream surveys should be
conducted between June 1st and October 15th.
81. Why are the smaller tributaries (Spanish Needle Creek and the unnamed tributary) not
assessed? These are used to water livestock and for other uses.
Spanish Needle Creek and the unnamed tributaries of Spanish Needle Creek are not
part of the IEPA’s Intensive Basins Survey rotation due to their small watershed sizes
and inability to provide permanent flow during the summer. While macroinvertebrates
may be present in isolated pools during drought conditions, fish instinctively move
downstream and therefore are not appropriately assessed under these conditions.
Larger watersheds, such as Macoupin Creek in this instance, are better candidates for
assessing the attainment of uses given that flow is not a limiting factor.
82. Has there been a biological study done of the creek and if so when?
The Illinois EPA conducted a facility related stream survey of Spanish Needle Creek on
September 28, 2010 which consisted of a physical, chemical, and biological
characterization of this stream upstream, downstream, and adjacent to the mine site.
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Groundwater Issues
83. On October 15, 2013, Illinois EPA requested new toxicity characteristic leaching procedure
tests on slurry. Do you know what the results of those tests are??
Yes, the mine has provided those results to the Illinois EPA. The purpose for
requesting the tests was to compare coal slurry to the coal combustion residue that the
mine accepts as CCB. The results indicate that the CCB and the coal slurry are similar,
with CCB having a higher pH, which allows it to provide neutralization, while the refuse
has much higher sulfur content.
Please see attached summary of the CCB Analytical Data.
84. Under a Memorandum of Understanding between Illinois EPA and IDNR that some of the
responsibilities under SMCRA, namely for groundwater protection, has been delegated from
IDNR to Illinois EPA. If either the nondegradation standard or groundwater quality standards
are exceeded either on or off-site at Shay 1 Mine, whose responsibility is it to issue a violation
notice to request inspection or to request additional sampling and so forth?
If there was a new exceedance (i.e. one that did not fall within the scope of the consent
order) it would be the Illinois EPA that would issue violation notices, or required
additional activities with regard to groundwater.
85. Are groundwater quality standards being met at Refuse Disposal Areas 1-4?
There are groundwater quality standard exceedances throughout the site.
86. Are coal combustion byproducts allowed at RDA 5 and 6 and if so, do you know in what
volumes?
Yes. Currently, only the volume of CCB required for neutralization is allowed. However,
as part of the corrective action plan, the mine may accept as much as 1.5 million tons of
CCB annually. Acceptance of CCB as fill has not yet been approved by the Department
of Natural Resources.
87. What is the most recent analysis of the leaching potential of the coal combustion byproducts
and what test was used?
The analyses for CCB to demonstrate compliance with Section 3.135 of the Act (415
ILCS 5/3.135), using test method ASTM D-3987-85, must be reported to the Department
of Natural resources annually by January 31st. The last available CCB analysis is from
January 2015. Please see attached information on the CCB analysis from January 2015.
29
88. What is the water quality characterization of the waste streams regarding RDA 5 and 6?
Where would the water from these waste streams go?
Several samples of leachate (slurry circuit water) were collected and a statistical
method was used to calculate a tolerance limit. The tolerance limit provides an estimate
of the maximum concentration of each chemical constituent that would be expected to
occur. These maximum estimated concentrations were assumed to be the actual
concentration that would exist.
For RDA 5, as proposed, there is gravity flow from RDA 5 out of the drainage layer to
Smith Lake. The RDA 6 waste water flow has not been proposed yet, since water is still
pumped from RDA 6 as make-up water for the mining operation.
89. Was it known prior to the purchase of the mine that there was off-site contamination?
Prior to buying the mine in 2009, there was no information that demonstrated off-site
contamination. Off-site contamination was proven as part of investigations required
under the site remediation program (SRP).
90. Do you monitor for groundwater contamination in respect to the coal slurry?
No groundwater monitoring relative to the underground slurry disposal is required.
91. If there is a contamination to groundwater from coal slurry, is there a way to remediate that?
The current groundwater problem is partially caused by slurry that was stored above
ground. Injecting slurry into the abandoned mine works is not expected to cause
contamination of any source or future source of drinking water. The State Geological
Survey has created maps statewide that display the elevation underground where
sources of drinking water (fresh water) occur.
In the area of the Shay #1 mine, the greatest depth below the ground surface where
fresh water exists is 50-100 feet above the Number 6 Coal, which is the coal member
being mined. Therefore, the mine voids being used for slurry disposal will not pose a
hazard to current or potential sources of drinking water. Since the slurry is not
pressurized in the mine void and much of the water that carried slurry is pumped back
into the mines water circuit, there is nothing to cause the slurry to migrate upwards
towards fresh water.
92. Why when you talk about NPDES chemicals for which you analyze, like chloride, sulfate,
manganese, iron, whatever, why aren't some of the more toxic components of coal, like
arsenic, cadmium, thallium, beryllium, lead, mercury, why aren't they analyzed or checked for
in groundwater and in surface water?
The groundwater monitoring required in this NPDES permit does require the beginning
of monitoring for those constituents. Please see NPDES Special Condition 14.
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93. Does the mine have an underground injection permit from the Illinois EPA?
The wells used to inject slurry are classified as Class V Injection Wells. Class V wells
are not required to obtain a permit. The underground injection control program at the
Illinois EPA does maintain an inventory of Class V wells.
94. Will the Illinois EPA be reviewing all plans for the trenching?
The Illinois EPA will review trenching plans.
Please, also refer to the response to Item No. 22 above.
95. There are a lot of room and pillar sections going north toward Carlinville, and that would be
north toward the gradient that appears to be draining toward Lake Carlinville, so without
knowing exactly the plan for the injection, we wonder how can Illinois EPA be certain that the
requirements to protect the public water supply lake be met?
Illinois EPA did consider the direction of the slope of the mine works into which slurry
is to be injected. Berms will be constructed in the mine works to limit the area into
which slurry can travel. Even if the berms were overtopped or the slurry somehow went
around the berms, the mine works is located 300 or more feet below land surface. Since
the slurry injection is not pressurized once it enters the mine void, there is nothing to
cause the slurry to migrate upwards towards Lake Carlinville. Additionally, the regional
slope of the coal seam in which the mine voids are located is to the southwest, not
towards Lake Carlinville.
96. There are room and pillar chambers under RDA 6 and under RDA 5 and the conglomeration
RDAs there, there’s room and pillar chambers going clear north quite a ways almost to Route
4. There have been roof falls at this mine, there have been concerns about stability of perhaps
some of the underground chambers. Is this a safe thing to do for the protection of the
groundwater for the future?
Please, also refer to Items No. 91 and 95 above.
97. Can you describe any changes in the abandonment plans for RDA 5 and 6? And will there be
opportunities for the public to see that and comment?
The corrective action plan requires the installation of wick drains and a drainage layer
to dewater the existing slurry and a final cover that will incorporate a low permeability
clay layer in both RDA 5 and RDA 6. The current abandonment requires only four feet
of soil. The mine will be required to obtain an Office of Mines and Minerals permit to
make these changes.
98. The Corrective Action Plan that was received June 10, 2013; how does that plan relate to the
May, 2012, Remedial Action Plan?
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The Remedial Action Plan (RAP) was a submission, required under the SRP. The
Corrective Action Plan is a modification of the RAP, which includes changes required
by the Illinois EPA to better protect groundwater. The Corrective Action Plan was
developed to address the groundwater standards exceedances that were the subject of
the violation notice W-2011-00040.
99. What analysis has IEPA performed to show that the plan to dispose of coal refuse
underground won't further result in groundwater contamination?
Please refer to the responses to Items. No. 91 and 95 above.
100. As for protection of existing and designated groundwater uses, it appears that the Illinois EPA
maintains that groundwater quality standards do not apply under a mining site within the
permitted area per 35 Ill Adm. Code Section 620.240(f) which states that “Groundwater which
underlies a coal mine refuse disposal area not contained within an area from which overburden
has been removed, a coal combustion waste disposal area at a surface coal mine authorized
under Section 21(s) of the Act, or an impoundment that contains sludge, slurry, or precipitated
process material at a coal preparation plant, in which contaminants may be present, if such an
area or impoundment was placed into operation after February 1, 1983, if the owner and
operator notifies the Agency in writing, and if the following conditions are met:”. We maintain
that sufficient evidence exists that shows that subsections 2), 3) and 4) are not being met at
Shay No. 1, meaning that groundwater existing under the coal refuse area does not meet the
criteria to be considered “Class IV: Other Groundwater” and instead should have to meet
criteria and protections for Class II groundwater. The following requirements to be classified as
Class IV: Other Groundwater found at 35 Ill Adm. Code Section 620.240(f) have not been met:
2. The source of any release of contaminants to groundwater has been controlled
3. Migration of contaminants within the site resulting from a released to
groundwater has been minimized;
4. Any on-site release of contamination to groundwater has been managed to
prevent migration off-site;”
The violation notice W-2011-00040 issued by the Illinois EPA and the complaint filed
by the Illinois Attorney General allege violations of the Class I and Class II
groundwater quality standards. Macoupin Energy and the State are finalizing a
consent order that incorporates a corrective action plan (CAP) that will remediate
groundwater beyond the foot print of the RDAs to achieve the Class I and Class II
standards. The Illinois EPA believes that implementation of the CAP will meet the
criteria of 35 Ill. Adm. Code 620.240(f) (2), (3) and (4)
101. Has there been or will there be any analysis of groundwater for toxic chemicals such as
arsenic, beryllium, boron, cadmium, chromium, lead, mercury, nickel, selenium, or
polycyclic aromatic hydrocarbons (PAHs), since they are commonly found in coal refuse?
We recommend that Outfalls 002, 005 and 007 be monitored quarterly for these chemicals.
32
This permit requires groundwater monitoring of the 35 Ill. Adm. Code 620.410(a)
constituents with the exception of radium 226 and 228, and perchlorate. Please see
NPDES permit Condition 14.
102. In the construction authorization dated August 23, 2010, Special Condition 14 requires
groundwater monitoring for constituents from Aluminum to Zinc. Has this sampling been
required before? Has the Illinois EPA seen groundwater monitoring values for those
pollutants before? Why doesn’t the Illinois EPA require this monitoring to be conducted
prior to issuance of the permit?
The groundwater monitoring required in this permit has not been required before at
this mine, but has become a standard requirement for new mine permits. Since the
permit for this mine has not been renewed for some time, the requirements
contained in Condition 14 are being incorporated into this permit. Having new
requirements, such as monitoring, take effect coincident with the issuance of
permits makes tracking of the requirements simpler and also provides an
enforceable document to contain the requirement.
103. How can this site be in the SRP when 35 Ill. Adm. Code 740.105 says that places cannot
be in the program if they are under current state or federal permits?
35 Ill. Adm. Code 704.105(a)(2) states that “ one cannot use the SRP program
if: “The investigative and remedial activities for which Agency review, evaluation
and approval are requested are required under a current State or federal solid or
hazardous waste permit or are closure requirements for a solid or hazardous waste
treatment, storage or disposal site under applicable State or federal laws and
implementing regulations.” In this case, this section does not apply to the Shay
mine. The site does not have any requirements under a current State or federal
solid or hazardous waste permit or are closure requirements for a solid or hazardous
waste treatment, storage or disposal site under applicable State or federal laws and
implementing regulations.
104. Is the remediation site or any other part of the site currently polluting surface or
groundwater?
Yes, violation notice W-2011-00040 was issued for alleged exceedances of the Part
620 groundwater quality standards. These alleged violations resulted in a referral to
the Illinois Attorney General’s Office. The Illinois Attorney General’s Office, the
Illinois EPA and Macoupin Energy are finalizing a consent order to address the
alleged groundwater violations. Monitoring at surface gauges, which are completed
as part of site investigations under the SRP, do not indicate exceedances of surface
water quality standards.
105. Where is the Groundwater Monitoring Zone (GMZ) located?
33
The GMZ will be located as described in the GMZ application, submitted after the
consent order is finalized. In general, the GMZ will be all of the mine property north
of Spanish Needle Creek.
106. Are there any potable wells located within the SRP site or the GMZ?
Macoupin Energy must withdraw from the SRP as a condition of the consent order
and the GMZ is entirely on mine property. There are no potable wells on the mine
property.
107. Where are the onsite groundwater monitoring wells located?
There are monitoring wells located throughout the site and some off-site too. Please
see the attached map.
108. Can you tell me how impoundments one through six are lined? Do they have plastic liners
or is it four foot of clay?
Impoundments one through six are unlined. All of these impoundments were
constructed before the use of liners became a common practice.
109. Which class of groundwater quality standards would the groundwater directly under the
RDAs be held to?
110. Is the difference in the applicable groundwater standards for RDA5 and RDA6 due to their
age?
Yes, but that difference only applies within the foot print of the impoundments.
Please see 35 Ill. Adm. Code Section 620.450(b).
111. Has the owner or operator of the site notified the Illinois EPA that the source of any release
of contaminants to the groundwater has been controlled as per condition 2 of 35 Ill. Adm.
Code 620.240 (f)(2) and (3)?
Please refer to the response in Items No.100 and No. 104 above.
112. Have there been analysis of toxic materials (i.e. lead, cadmium, selenium, arsenic, and
PAHs) for exceedance of Class I groundwater standards?
Groundwater has not been monitored for those constituents.
Also, please refer to the responses in Items No.101 and No. 102 above.
113. How many private drinking water wells are located in the vicinity of the Shay No. 1 Mine?
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Based on information provided in the remedial objectives report submitted under the
SRP, the Illinois EPA does not believe there are any drinking wells in use in the
vicinity of the RDAs
114. Where and how far has the contamination migrated off of the NPDES permit site?
Contaminants have migrated at least 500 feet, but less than 1,000 feet west and
northwest of RDA5.
115. Is the groundwater around the impoundments tested for arsenic, mercury, etc?
This permit contains requirements to monitor for a wide range of contaminants in
the groundwater monitoring wells; however, metals other than iron and manganese
are not currently part of the monitoring requirements.
Also, please refer to the responses to Items No. 101 and 102 above.
116. What chemicals constituents are being leached into the groundwater and do they pose a
risk to adjacent landowners?
Violation notice W-2011-00040 alleged groundwater standards exceedances of iron,
manganese, sulfate, chloride and total dissolved solids in samples from various
monitoring wells. With the exception of manganese, these constituents cause water
to have objectionable taste, odor and appearance, but have no long term health
effects. Manganese can have health effects at certain levels, however it is noted that
up gradient wells, unaffected by the mine, also exceed the manganese groundwater
standard.
117. How can I review the results from the monitoring well on my property?
Monitoring well results can be obtained by submitting a Freedom of Information Act
request to the IDNR.
118. Is Spanish Needle Creek currently being impacted by groundwater contamination at the
mine? If so, why are there no special conditions to give this creek every possible protection
from additional pollution that can be provided in an NPDES permit?
There is no information that indicates groundwater contamination is impacting
Spanish Needle Creek. Monitoring at surface gauges, which was completed as part
of the site investigations under the SRP, do not indicate exceedances of surface
water quality standards.
119. On page 17, Special Condition 14G deals with the determination of whether a statistically
significant change has occurred in the groundwater. What information did you obtain
through this condition?
35
Condition 14(g) of this NPDES permit addresses actions, which are required by the
permitee, but this requirement does not take affect until the NPDES permit is issued.
Therefore, condition of 14(g) of this permit, at this time, has not provided the Illinois
EPA information. Once the permit is issued, the permitee will be required to follow
the requirements found in Condition 14(g) of the NPDES permit.
120. Has the Illinois EPA taken any steps to let the owners of private drinking water wells
located in the vicinity of the Shay No. 1 Mine know that there’s groundwater contamination
both onsite and moving offsite?
Based on the information contained in the remedial objectives report for the SRP,
the Illinois EPA is not aware of there being any drinking water wells within the
vicinity of the RDAs. The Illinois EPA believes all residents near the mine are served
by a community water supply.
Enforcement/Compliance Issues
121. In your assessment, is Smith Lake considered a water of the state of Illinois?
The Illinois EPA has determined this that Smith Lake is not a “waters of the state”.
Please also refer to the responses found in Items No. 28 and No. 29 above.
122. Macoupin Energy fails to meet requirements for protected waters of the state of Illinois. The
renewal of the NPDES permit violates Illinois law because the mine is unlawfully using
Smith Lake, a “waters of the state,” as a treatment works. Title 35 of the Illinois
Administrative Code, Section 301.440 states that nothing contained in the Environmental
Protection Act or Administrative Code “shall authorize the use of natural or otherwise
protected waters as sewers or treatment works….” In this case, Macoupin Energy has
impounded natural waters for use as a pond to dilute effluents from activities on the Shay 1
mine. That impoundment has been termed “Smith Lake” or “Smith Reservoir.” (E-17) What
legal authority does the Illinois EPA or a private entity have to remove waters of the state
from protection under the CWA?
This water has not been removed from protection since it was always determined to
be a “treatment works”.
Please, also refer to response found in Items No. 28, No. 29 and No. 121 above.
123. Under what legal authority or regulation change or something, it was my understanding that
the original NPDES for this mine when it was Monterey 1 with Exxon said that the NPDES
permit could not be transferred and that a new permit would have to be obtained and, you
know, then it was transferred, the permit was transferred from Monterey Coal Company to
Macoupin Energy. Is IEPA aware of this?
36
Yes, the Illinois EPA is aware this permit was transferred. Monterey submitted their
renewal application dated March 20, 2000 pursuant to 35 Ill. Adm. Code 309.104. The
renewal application was received by the Illinois EPA on March 23, 2000. 35 Ill. Adm.
Code states, “any permittee who wishes to discharge after the expiration of his
NPDES permit shall apply for reissuance of the permit not less than 180 days prior to
the expiration of the permit.”
An effective permit was transferred in 2009 to Shay. This transfer was a name
change only. Such a change is considered a minor modification pursuant to 40
C.F.R. 122.63(d).
124. Water law 35 Ill Adm. Code 406.204 says that the mine must use good mining practices.
How can violations of the law be good mining practices?
The permit requires the permittee to use Good Mining Practices (GMPS) as required
in 35 Ill. Adm. Code Section 406.204. These requirements are outlined in the NPDES
permit on Page 15, Condition 11. GMPS are utilized to minimize the dissolved and
suspended solids in the runoff of the basins and subsequent discharge. The
permittee has proposed drainage control plan that has been approved under the
NPDES permit. This plan includes ditching of runoff from disturbed areas,
sedimentation basins, diverting runoff from unaffected areas around disturbed areas
to minimize additional contribution of suspended solids, erosion control measures
such as mulching, silt fence, straw bale dikes, etc., to demonstrate the permittee is
using good mining practices.
If there is a violation found concerning the conditions of the NPDES permit, the
Illinois EPA can take action against the permittee pursuant to Section 31 of the
Illinois Environmental Protection Act.
125. A letter from Illinois EPA to the mining company in January 2009 discusses the Illinois
EPA’s position not to take enforcement actions or levy monetary penalties as long as the
new operator makes good faith efforts to work within the bounds of the SRP and the GMZ
designations. Does this mean that Illinois EPA is not enforcing penalties or regulations?
The referenced 2009 letter is speaking in general terms with regard to the Illinois
EPA’s usual practice when a site is enrolled in the SRP. The letter does state that
the “Agency cannot relinquish its primary mandate of environmental protection. In
this light, the SRP and GMZ programs to not eliminate an owner or operator’s
potential liability for any worsening of the groundwater after the GMZ has been
established”.
The Illinois EPA did issue violation notice W-2011-0040 to Macoupin Energy. The
violation notice was subsequently referred to the Illinois Attorney General’s Office
due to the amount of time needed to complete the remediation at the mine. The
referral resulted in a consent order, which is being finalized by the State and
37
Macoupin Energy. The consent order will contain a penalty and requirements to
achieve compliance with groundwater regulations.
126. If an active RDA was unvegetated and showed significant signs of erosion along the
embankments that form the disposal area, would that be a violation of the permit?
The Illinois EPA would conduct a site inspection to determine if the RDA were
unvegetated and to determine the severity of the erosion to determine if there has
been a permit violation. If the inspection found a permit violation, the Illinois EPA
may issue a violation notice.
Site Remediation
127. How does Illinois EPA justify allowing Shay 1 mine site to be enrolled in the site
remediation program at the same time they are allowed to operate and add additional
pollutants to the very sources that they are, the very sources that are polluting groundwater
and surface water?
The Site Remediation Program rules do not prohibit sites like Shay #1 Mine from
entry into the program.
Reclamation
128. What are the reclamation plans to remove coal waste at RDA6 according to the Illinois
Administrative Code and the U.S. Federal Register rules?
The coal waste from RDA 6 is not required to be removed.
Reclamation
requirements can be found within Illinois Department of Natural Resources
regulations.
129. Who is responsible for cleanup when operations at this mine cease?
The Permittee is responsible for reclamation pursuant to 35 Ill. Adm. Code 405.110
when operations at this mine cease. The Illinois EPA must be notified within 30 days
if active mining will be suspended. During the suspended period all monitoring and
water control under the NPDES Permit must be maintained.
The cleanup/abandonment is detailed in the facility’s reclamation plan submitted in
accordance with 35 Ill. Adm. Code 405.109. Plan must demonstrate that post mining
violations of the Act will not occur. At that time, all discharges and runoff from the
site are required to meet the water quality standards.
130. According to the NPDES IL[#00]0056022, page 12 of log No. 5360-03 Outfall 006 was
reclaimed. How and when was it reclaimed?
38
Outfall 006 was an incised sediment pond at the East Intake Air shaft. Once the shaft
was installed and the mine had progressed through the shaft area the water was
diverted from outfall 006 into the underground workings of the mine. The pond was
then filled and re-vegetated around 2005.
131. How will the emergency spillway behave once reclamation of Outfall 005 is complete and
vegetative soil caps are in place?
South Holding Pond was designed to have a pipe as the primary discharge structure,
Outfall 005, and open channel emergency spillway for the active mining phase of this
operation. Reclamation plan for this basin is to remove the discharge structures and
backfill the basin with soil. The final stage of the reclamation plan will cover the
entire area with soil and this area will be left as undeveloped land and cropland.
132. When reclamation of Outfall 005 is complete will the spillway be closed so that it prevents
any water that’s still inside from running off?
In order for the reclamation of Outfall 005 to be complete, the basin must be
backfilled with soil, the spillway removed, and the whole area has been covered with
soil and revegetated. Runoff from the area will be a sheet flow runoff similar to a
runoff from naturally vegetated areas.
133. When did RDA5 stop receiving fine coal refuse for storage or disposal? When did RDA5
start the process of reclamation?
Refuse Disposal Area No. 5 reached its designed capacity for receiving fine coal
refuse in 1996 and fine coal refuse was sent to the newly constructed Refuse
Disposal Area No. 6. At this time, coarse coal refuse is used to start the reclamation
of Refuse Disposal Area No. 5 and dike construction of Refuse Disposal Area No. 6.
134. Log 2048-06 requested water transfers from RDA6 to RDA5. According to the Illinois
Department of Natural Resources, Department of Mines and Minerals RDA5 is currently in
final reclamation. Why is the transfer from RDA6 to RDA5 being proposed in this permit if
the area is in final reclamation?
Although RDA No. 5 is currently undergoing final reclamation, this structure remains
part of the approved water management plans. Therefore, until final reclamation is
complete, the option remains available for the mine to utilize any available water
storage or holding capacity in RDA No. 5 as part of the overall water management
plan.
Other Issues
135. Can I get NPDES results on Shay mine through a FOIA request?
39
The monitoring data sent to Illinois EPA by the mine is entered into the ICIS
(Integrated Compliance Information System) system maintained by USEPA. The
public has access to this data through a system called ECHO (Enforcement and
Compliance History Online). The website for ECHO is http://echo.epa.gov/#. Using
the NPDES permit number (IL0056022) ECHO will provide information on compliance
and enforcement. If ECHO fails to provide the needed data, a Freedom of Information
Act (FOIA) request may be filed with Illinois EPA. Instructions for filing a FOIA
request are found on the Illinois EPA website http://www.epa.illinois.gov/foia/.
136. We own land contiguous to the mine property and have been forced to close our residential
wells and tolerate material blowing into our work areas. Will this permit create more
problems for adjacent properties?
The Illinois EPA has made a decision to grant the permit pursuant to Section 39 of
the Illinois Environmental Protection Act. During the permitting process, the IEPA
must base its decision whether to prepare a draft permit and issue a final permit on
the application provided by the applicant and applicable regulations. The Illinois
EPA must base its permit decision on whether the applicant has provided
information that the applicant’s operation, procedures, equipment and discharge to
show that the discharge can consistently meet the state regulations. If so, the IEPA
is required by law to grant the permit. The facility will then be required to operate
within the limits in by the permit. In this case, it has been determined the applicant
can meet the requirements of the permit and applicable regulations. Should a
landowner or anyone else have concerns about the mine operation, the person can
contact the Illinois EPA and report those concerns.
The contact information for reporting issues or concerns is 217-782-3637.
137. Shay No. 1 Mine has a RCRA permit ILD098641012 and apparently generates
approximately four tons of hazardous waste per year. Does the Illinois EPA know what the
waste related practices are covered by the RCRA permit and how those practices might
impact surface and groundwater in the vicinity? Has this information been taken into
account in the NPDES permit?
Shay No. 1 Mine is a Conditionally Exempt Small Quantity Generator (CEQG) which
generates from 220 lbs. up to 2,200 lbs. of hazardous waste per month.
The
hazardous wastes generated are typical of industrial facilities and are managed in
containers. Therefore, they are not required to have a RCRA permit to manage the
waste. The ILD number above listed is a USEPA ID number, not a permit number.
The hazardous wastes generated at the facility include spent Aerosol cans, Universal
Waste Spent Fluorescent Lights, hazardous waste spent parts washer solvent, Used
Oil, and hazardous waste lab packs from a no longer functioning lab or other work
done on-site generating very small amounts of waste. Since these hazardous
wastes are not part of the waste stream discharged pursuant to the NPDES Permit,
they have not been considered in the NPDES Permit.
40
138. How long has this mine been operating?
Macoupin Energy, LLC, and its labor contractor, MaRyan Mining, have operated this
facility since 2009. Prior to 2009, the mine was operated by Monterey Coal Company,
dating back to the 1960s.
139. How many acres does RDA6 cover and how deep is it? Has the crest of RDA6 been raised
from 701 feet to 705 feet?
RDA 6 is approximately 220 acres of surface area. Its bottom elevation is
approximately 610 feet at its lowest point. The top permitted elevation is 705 feet,
making it less than 100 feet tall. The dam was modified to raise the crest elevation of
the dam to allow for continued disposal of fine coal refuse slurry into the dam
interior.
140. It is stated on page 19, special condition no. 5 that CCW analyses is required. Does this
mean that CCW or coal slurry will be injected underground in mine voids?
Currently, there is no coal combustion waste (CCW) disposal at this facility, nor has
there been an application submitted to the Illinois EPA for CCW disposal.
Furthermore, Illinois EPA has not received any application for underground injection
at this facility.
141. I have submitted a series of photos documenting an oil like film and red to orange looking
substance on the water in Spanish Needle Creek. Were these photos or conditions
inspected? If so, what were the results?
The Illinois EPA contacted IDNR/OMM regarding this concern and the following
information was provided: IDNR/OMM conducted downstream sampling in response
to a complaint concerning an oily film on the water surface and “red muck” in
Spanish Needle Creek downstream of the mine. The samples collected were
analyzed for metals, anions by Ion Chromatography, acidity, alkalinity, ammonia, pH,
total dissolved solids, and total suspended solids. The sample results were within
the approved range set by the NPDES permit for Shay Mine’s discharge points
upstream of these sample locations. Later, IDNR/OMM staff collected additional
samples for hydrocarbons at the same locations. The samples were analyzed for
volatile organic compounds, semi-volatile organic compounds, and total petroleum
hydrocarbons. No substances tested for were detected.
IDNR/OMM concluded that the oily substances observed on the water surface is
likely natural organic materials resulting from decomposition of detritus and the “red
muck” observed was most likely a natural biofilm.
41
142. Does this facility have a land permit that would affect their ability to be accepted into the
SRP?
This facility does not have a permit under any Bureau of Land Program.
143. Is a permit under the Resource Conservation Recovery Act (RCRA) a land permit?
A permit under RCRA is a permit under a Bureau of Land Program.
144. To have constructed RDA6 on a tributary to Spanish Needle Creek , Exxon Moil would
have needed to secure a Section 404 permit from the Army Corps of Engineers, under the
CWA. To my knowledge this permit was not obtained from the Corps. Was this permit
ever obtained?
In a letter dated July 21, 1988, the Army Corps of Engineers (COE) responded to the
mine’s application requesting authorization under Section 404 of the Clean Water
Act for the placement of fill material into waters of the United States in conjunction
with the construction of RDA 6 by issuing Nationwide Section 404 Permit Number 21.
42
Acronyms and Initials
CAP
Corrective Action Plan
CCA
Compliance Commitment Agreement
CCB
Coal Combustion By-product
CCW
Coal Combustion Waste
CFR
Code of Federal Regulations
COE
Corps of Engineers
CWA
Clean Water Act
DMR
Discharge Monitoring Report
ECHO
Enforcement and Compliance History Online
FOIA
Freedom of Information Act
GMZ
Groundwater Monitoring Zone
GPM
Gallons per Minute
ICIS
Integrated Compliance Information System
IDNR
Illinois Department of Natural Resources
IEPA
Illinois Environmental Protection Agency
ILCS
Illinois Complied Statutes
IPCB
Illinois Pollution Control Board
Ill. Adm. Code Illinois Administrative Code
mg/L
Milligrams per liter
MSDS
Material Safety Data Sheet
MSHA
Mine Safety and Health Administration
NPDES
National Pollutant Discharge Elimination System
43
OMM
Office of Mines and Minerals
pH
A Measure of Acidity or Alkalinity of a Solution
PAH
Polycyclic Aromatic Hydrocarbon
RAP
Remedial Action Plan
RCRA
Resource Conservation Recovery Act
RDA
Refuse Disposal Area
SMCRA
Surface Mining Control and Reclamation Act of 1977 (federal)
SRP
Site Remediation Program
TDS
Total Dissolved Solids
TCLP
Toxicity Characteristic Leaching Procedure
TMDL
Total Maximum Daily Load
TSS
Total Suspended Solids
44
DISTRIBUTION OF RESPONSIVENESS SUMMARY
An announcement, that the NPDES permit decision and accompanying responsiveness
summary is available on the Illinois EPA website, was mailed to all who registered at the
hearing and to all who sent in written comments. Printed copies of this responsiveness
summary
are
available
from
Barb
Lieberoff,
217-524-3038,
e-mail:
[email protected].
WHO CAN ANSWER YOUR QUESTIONS
Illinois EPA NPDES Permit:
Illinois EPA NPDES technical decisions:……………….Iwona Ward ...... 618-993-7200
Legal questions .................................................... ……Stefanie Diers ... 217-782-5544
Water quality issues ............................................. ……Brian Koch ........ 217-558-2012
Groundwater issues ............................................. ……Lynn Dunaway .. 217-785-4787
Public hearings of April 27, 2011 and March 11, 2014.Dean Studer...... 217-558-8280
Documents from this proceeding, including the final NPDES permit and the
responsiveness summary are available on the Illinois EPA website (note that if you get
an error message, you may have to paste the website address into you browser
window):
45
Attachment for Response to Item No. 83
Sample Collection Date
1/17/2013
1/17/2013
ADM Fly Ash and Bed Ash
Shay No. 1 Coarse/Fine Refuse Composite
Tate & lyle Fly Ash and Bed Ash
I
I
"o.oo1 I
1660
0.59
106
I
I C
Comparison of Analyses From D3987 Shake Extract
(and Total Sulfur for Coal Refuse Composites)
10/23/2013
Cyanide
Sulfate
Fluoride
Chloride
Aluminum
TDS
Molybdenum
Vanadium
[SUlfur
< 0.007
1750
0.15
126
I
I
ADM
1/11/20U
2700
12.4
Fly Ash
ADM
Bed Ash
3/12/2012
ADM
< 0.005
2300
12.4
1/11/2013
ADM
2.0000
0.0041)
2.0000
0.0050
0.1000
1.0000
0.6500
0.1000
Applicable Class I
Groundwater
Standard (620.410)
mg/1
mg/1
mg/1
mg/1
mg!'l
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
Units
Expanded Testing Results
Fly Ash
< 0.005
420
420
-2100
50000
mg/1
mg/1
Bed Ash
3/12/2012
292
292
-2500
0.159
< 0.0010
0.212
<. 0.0020
0.0089
< 0.0100
< 0.0100
< 0.0100
< 0.0100
< 0.0100
0.0036
< 0.0100
00060
O.DlOO
0.0075
0.0500
0.0020
0.2000
400
4
200
1200
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
m_gLI
0.0490
0.1500
0.1000
00500
5.0000
0.237
< 0.0010
0.0914
< 0.0020
0.08 2
< 0.0100
< 0.0100
< 0.0200
< 0.0050
< 0.0100
0.0042
0.0023
< 0.0020
< 0.0050
< 0.0030
0.0022
< 0.0060
mg/1
mg/1
mg/1
0.0024
< 0.0030
0.0029
0.0102
0.0008
0.0020
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/kg
I
<0.00020
<0.007
1580
0.22
15
< 0.007
103
0.59
11
4930
0.041
0.0214
<0.01
1o5ooo
I
< 0.00020
- --- ·-
< 0.007
1700
3.44
123
I
1/17/2013
1/17/2013
Attachment for Response to Item No. 87
MACOUPIN
ENERGY
LLC
Mr. Scott Fowler
Illinois Department of Natural Resources
Office of Mines and Minerals, Land Reclamation Division
One Natural Resources Way
Springfield, Illinois 62702-1271
Re: Permit No. 56, Insignificant Revision No. 106
Permit No. 209, Insignificant Revision No. 25
January 23, 2015
i:.
~ ~{.:_ (:~ E ~-'~J tS Y:.l
l)t;r.·T ,::,r: :".; .~;· r lP.r\.L~. R~5C=U P~C·ES
,,.r,, ::
(;rr~l~;.i: (~; F
tL r,', ;";.f~ l_ \,
!'/itr<:r.s e{ r~:rl\ER~LS
LM.;( } Lf(. U.~·:..\TtON DIViSION
Dear Mr. Fowler,
As per condition number 1 in IDNR's approval letter dated November 17, 2011, which
states "Each CCB source shall be analyzed for chemical constituents according to
methods defined in Land Reclamation Division Memorandum 95-8 to verify the CCB
continues to meet requirements for CCB. The analyses shall also include an acid base
account of each CCB material. The testing shall be done beginning on January 31,
2013 and then annually thereafter for as long as the CCB is being utilized."
Macoupin is currently approved to receive ADM and Tate & Lyle fly and bottom (bed)
ash. Enclosed are the required analysis for ADM and the calculation sheet to achieve a
balanced net neutralization.
Please note that only ADM ash analysis was used for the net neutralization balance
calculation because it is the only ash we currently have a contract to receive. However
we did not conduct the analysis on the Tate & Lyle ash as we are currently not doing
business with them. If and when we gain their business the required analysis will be
conducted and a new calculation sheet will be amended and submitted.
If you have any questions concerning this report, please contact me at 217-899-1926.
Sincerely,
l!zu~~
Director of Engineering
MaRyan Mining, LLC
http://www.teklabinc.com/
January 19,2015
Danielle Mullendore
Hanson Professional Services, Inc.
1525 South Sixth Street
Springfield, IL 62703
TEL: (217) 747-9375
FAX: (217) 788-5241
RE: 13E0032G/l 000
WorkOrder: 15010505
Dear Danielle Mullendore:
TEKLAB, INC received 1 sample on 1113/2015 1:55:00 PM for the analysis presented in the
following report.
Samples are analyzed on an as received basis unless otherwise requested and documented. The
sample results contained in this report relate only to the requested analytes of interest as
directed on the chain of custody. NELAP accredited fields oftesting are indicated by the letters
NELAP under the Certification column. Unless otherwise documented within this report,
Teklab Inc. analyzes samples utilizing the most current methods in compliance with 40CFR.
All tests are performed in the Collinsville, IL laboratory unless otherwise noted in the Case
Narrative.
All quality control criteria applicable to the test methods employed for this project have been
satisfactorily met and are in accordance with NELAP except where noted. The following report
shall not be reproduced, except in full, without the written approval ofTeklab, Inc.
Ifyou have any questions regarding these tests results, please feel free to call.
Sincerely,
Marvin L. Darling
Project Manager
(618)344-1004 ex 41
\lEP.·r
F1~ ~:: (~: .E }l ~tl E ~~J;
(~;:· ~~~-~---:,., ~ 8 :\ L
RE.S(Y.JRC't.S
~. r.:!:· .- ,,~ ~ ;;;: ~lc:t r~
mdarling@teklabinc. com
OfFICE Gf
~·::{ ii\: f:-.~ f~::
h{II'iERA.L$
LL).!~[) :-\ ~C L~~~< .·\·rr.c~~ ~~ ~~P. -'. t S!O>J
Paget of'6
Report Contents
http: f/www.teklabinc.com/
Client: Hanson Professional Services, Inc.
Work Order: 15010505
Client Project: 13E0032G/1000
Report Date: 19-Jan-15
This reporting package includes the following:
Cover Letter
Report Contents
2
Definitions
3
Case Narrative
4
Laboratory Results
5
Receiving Check List
6
Chain of Custody
Appended
Page 2oF6
ekiab~Inc.
Definitions
htto:flwww.teklabinc.com/
Envlronmctntalt..aborarory
Client: Hanson Professional Services1 Inc.
Abbr Deimition
CCV Continuing calibration verification is a check of a standard to determine the state of calibration of an Instrument between recalibration.
DF Dilution factor is the dilution performed during analysis only and does not take into account any dilutions made during sample preparation. The
reported result is final and includes all dilutions factors.
ON! Didnotignite
DUP Laboratory duplicate is an aliquot of a sample taken from the same container under laboratory conditions for independent processing and analysis
independently of the original aliquot.
!CV Initial calibration verification is a check of a standard to determine the state of calibration of an instrument before sample analysis is initiated.
IDPH IL Dept of Public Health
LCS Laboratory control sample, spiked with verified known amounts of analytes, is analyzed exactly like a sample to establish intra-laboratory or analyst
specific precision and bias or to assess the performance of all or a portion of the measurement system. The acceptable recovery range is in the QC
Package (provided upon request).
LCSD Laboratory control sample duplicate is a replicate laboratory control sample that is prepared and analyzed in order to determine the precision of the
approved test method. The acceptable recovery range is listed in the QC Package (provided upon request).
MB Method blank is a sample of a matrix similar to the batch of associated sample (when available) that is free from the analytes of interest and is
processed simultaneously with and under the same conditions as samples through all steps of the analytical procedures, and in which no target
analytes or interferences should present at concentrations that impact the analytical results for sample analyses.
MDL Method detection limit means the minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte
concentration is greater than zero.
MS Matrix spike is an aliquot of matrix fortified (spiked) wfth known quantities of specific analytes that is subjected to the entire analytical procedures In
order to determine the effect of the matrix on an approved test method's recovery system. The acceptable recovery range is listed in the QC
MSD Matrix spike duplicate means a replicate matrix spike that is prepared and analyzed in order to determine the precision of the approved test method.
The acceptable recovery range is listed in the QC Package (provided upon request).
MW Molecular weight
NO Not Detected at the Reporting lJmit
NELAP NELAP Accredited
POL Practical quantitation limit means the lowest level that can be reliably achieved within specified limits of precision and accuracy during routine
laboratory operation conditions, The acceptable recovery range is listed in the QC Package (provided upon request).
RL The reporting limit the lowest level that the data is displayed in the final report. The reporting limit may vary according to customer request or sample
dilution. The reporting limit may not be less than the MDL
RPD Relative percent difference is a calculated difference between
two recoveries (ie. MS/MSD). The acceptable recovery limit is listed in the QC
SPK The spike is a known mass of target analyte added to a blank sample or sub-sample; used to determine recovery deficiency or for other quality
control purposes.
Surr Surrogates are compounds which are similar to the analytes of interest in chemical composition and behavior in the analytical process, but which are
not normally found in environmental samples.
TNTC Too numerous to count ( > 200 CFU)
Qualifiers
#- Unknown hydrocarbon
B-
Analyte detected in associated Method Blank
E - Value above quantitation range
H-
Holding times exceeded
J - Analyte detected below quantilation limits
M - Manual Integration used to determine area response
NO - Not Detected at the Reporting Limit
S-
Spike Recovery outside recovery limits
R- RPD outside accepted recovery limits
X- Value exceeds Maximum Contaminant Level
Page3of6
ekiabinc.
Case Narrative
http: I /www.teklabinc.com f
En.vlronm&llltZt Laboratory
Client Project: 13EOD32G/1000
Cooler Receipt Temp: 20.6 °C
Locations and Accreditations
Collinsville
Address
Springfield
Kansas City
Collinsville Air
8421 Nieman Road
5445 Horseshoe Lake Road
3920 Pintail Dr
Collinsville, IL 62234-7425
Springfield, IL 62711-9415
Lenexa, KS 66214
:Phone
(618)344-1004
(217) 698-1004
(913) 541-1998
(618) 344-1004
Fax
Email
(618)344-1005
(217) 698-1005
(913) 541-1998
(618) 344-1005
[email protected]
[email protected]
[email protected]
[email protected]
State
Dept
Cert#
NELA:P
ExpDate
Lab
Tilinois
!EPA
100226
NELAP
1/31/2015
Collinsville
CollinS\-ille
Kansas
KDHE
E-10374
NELAP
4/30/2015
Louisima
LDEQ
166493
NELAP
6'30/2015
Collinsville
Louisiana
LDEQ
166578
NELAP
6/30/2015
Collinsville
Texas
TCEQ
Tl04704515-12-l
NELAP
7131/2015
Collinsville
Arkansas
ADEQ
88-0966
3/!4/2015
Collinsville
Dlinois
IDPH
17584
5131/2015
Collinsville
Kentud:y
KDEP
98006
12131!2015
Collinsville
Kentucky
UST
0073
1/31/2015
Collinsville
Missouri
MDNR
00930
513112015
Collinsville
Oklahoma
ODEQ
9978
8/3112015
Collinsville
Page4of6
ekiabinc.
Laboratory Results
envlronma~ Laboratory
http: I lwww.teklabinc.com/
Client Sample ID: Fly Ash (ID: 1036)
Lab ID: 15010505-001
Matrix: SOUD
Analyses
Collection Date: 01/06/2015 8:48
Certification
RL
Qual
Result
Units
DF
Date Analyzed Batch
ASTM 03987, STANDARD METHODS 2310 BIN SHAKE EXTRACT
Acidity, Total (as CaC03)
-100000
-2490
mg/l
01/1512015 17:30 R199844
ASTM D3987, STANDARD METHODS 2320 B IN SHAKE EXTRACT
Alkalinity, Total (as CaC03)
0
2520
mgfl
01/15/2015 17:30 R199830
ASTM D3987, SW-846 9040 B, IN SHAKE EXTRACT
pH
12.7
ASTM D3987, SW-846 9066, IN SHAKE EXTRACT
Phenol, SHAKE
0.005
< 0.005
EPA 600/2-78-54 SLURRY
Neutralization Potential
0
EPA 670 2-74-70 SLURRY
Net Neutralization
0
mg/L
01/15/2015 14:38 R199812
289
CaC03T/KT
01/16/2015 8:00 R199873
289
CaC03 T/KT
01/16/2015 8:00 R199874
ASTM D3987, SW-846 3005A, 60108, METALS IN SHAKE EXTRACT BY ICP
Barium
0.202
0.005
Beryllium
0.001
< 0.001
Boron
0.02
0.264
Cadmium
< 0.002
0.002
Chromium
0.01
0.0583
Cobalt
0.01
< 0.01
0.01
Copper
< 0.01
Iron
0.02
< 0.02
Manganese
0.005
< 0.005
0.01
Nickel
< 0.01
< 0.()1
Silver
0.01
0.01
J
0.0073
Zinc
ASTM 03987, SW-846 3005A, 6020A, METALS IN SHAKE EXTRACT BY ICPMS
Antimony
0.001
NELAP
< 0.001
Arsenic
NELAP
0.001
< 0.001
Lead
NELAP
0.001
0.0026
NELAP
Selenium
0.01
0 .001
Thallium
NELAP
ASTM D3987, SW-846 7470A IN SHAKE EXTRACT
Mercury, SHAKE
01114/2015 20:42 105419
01115/2015 13:06
01/1512015 13:06
01/15/2015 13:06
01/15/2015 13:06
01/15/201513:06
01/15/2015 13:06
01/15/2015 13:06
01/15/2015 13:06
01/15/201513:06
01/15/2015 13:06
01/15/201513:06
mg/L
mg/L
mgfl
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
105444
105444
105444
105444
105444
105444
105444
105444
105444
105444
105444
01/15/2015 13:06 105444
mg/L
mg/L
mg!L
5
mg/L
mg/L
5
01/15/201518:20 105445
01/15/2015 18:20 105445
5
01/15/2015 18:20 105445
5
01/1512015 18:20 105445
01/15/2015 18:20 105445
0.001
< 0.001
mg/L
mgfl
0.0002
< 0.0002
mg!L
5
01/15/2015 11 :22 105446
Page5of6
http:flwww.teldabinc.com[
Client: Hanson Professional services, Inc.
WorkOrder: 15010505
Canier: Kelly Klostermann
Completed by:
On:
13-Jan-15
Received By: SRH
~ fd?v---
Reviewed by:
On:
13-Jan-15
Emily E. Pohlman
Pages to follow:
Chain of custody
1
Shipping container/cooler in good condition?
Type of thermal preservation?
Chain of custody present?
Extra pages induded
Yes D
None ~
Yes ~
Chain of custOdy agrees with sample labels?
Yes ~
Yes ~
Samples in proper container/bottle?
Yes
Sample containers intact?
Yes ~
Yes
Chain of custody signed when relinquished and received?
Sufficient sample volume for indicated test?
All samples received within holding time?
0
0
Yes~
Reported field parameters measured:
Field0
Contain·erfremp Blank temperature in compliance?
Yes
0
Elizabeth A. Hurley
1
NoD
0
Ice
NoD
Not Present
0
Temp
Blue Ice
0
Dry Ice
•c
20.6
D
NoD
NoD
NoD
NoD
NoD
NoD
NA0
0
lab
No0
When thermal preservation is required, samples are compliant with a temperature between
0. 1"C ;. 6. o•c, or when samples are received on ice the same day as col/ectsd.
Water- at least one vial per sample has zero headspace?
Yes
Water - TOX containers have zero headspace?
Yes
Water- pH acceptable upon receipt?
Yes
NPDES/CWA TCN interferences checked/treated in the field?
Yes
No VOA vials
0
0
0
0
No TOX containers ~
NA 0
NA~
Any No responses must be detailed below or on the COG.
The sample was out of temperature compliance upon receipt. Danielle Mullendore was notified of this error via workorder summary.
Page 6of6
CHAIN OF CUSTODY RECORD
... -.
.
---
--
..
1
·~
- ·-·· .
I
I •
..
- ---·-
- -·-·
-- . ...... .
··- -
... ··----
( I 0·~-l~~-~ )
-· ..
--.
--
./V1
Rclinquishnd b)' (signature);
- -·
-
I . II
·
'
~
~
0
•
S'
u
-~
Type
~
Time
Collected
.' :
~
(JJ
~
Q)
-;::
n1
.5
0
QJ
k
u
....0
/
~~
r·ln
.. !
.,
I
,.
.: .
~t ~-
1'
: • ' ..
~ 1 r«: 1~\ r ·p
) [_ '/ . ~\ ~i' · ~ ~
(/)()
ei
J
-r
11rvw
1
tiN
·
ff
1.5o)o~D~·
~HANSON
Remarks
See attached. Routine turnarc und
Danielle Mullendore
(217) 747-9375
(21 7) 788-2503
13E0032G/1 000
."Jo u.1.T~.; ~·: ·. .--~; ~:-~~~ ._, -~~ ,
Contact Name:
TelephoneNo.:
Fax No.:
ttf
eJro
Analyses
Desired
ProjectiD/PO:
X
/W'}r,tor:..,;)
-
rY--c u e,cn•"!L<A.
~ ~z
....
QJ
Matrix
lil
~
X
!\A' tV.....,
-"'~ r.
'?:X' 1'{;.r,f!,b.,._./
Date
Collected
.
'·
e>l·~[tt'y .X
Date/ Time
1
/., ) 3 .
1
'512~l>J1-.l..J4
Da e/ Time
i ( •I',f I' 5
1 (
1/tc)/S
Sampler (signature):
·------------------------
___!'Jla!3y~~ Mining LLC
--~-----------------------_t!?_rl§Q[l Professional Services Inc.
1525 South 6th Street
·springfield, Illinois 62703
CLIENT INFORMATION:
Client:
Address:
'
A<; h
Sample Description
-·
Sampler-(plcasc priili~ ·
SAMPLE INFORMATION:
/
~p~
IJ\0
11
. "
~)\ "Fil1
,.
f'• .. ..:' r '
q
. . .-v .Reli~cd
. ~ - ,f I byLv.f,J......v,...
(si\;l{ature):
MI~R"Zl..
Testing Sample Parameters
LRD Memorandum 95-8 (Beneficial Use)
•
•
•
•
•
•
•
•
•
•
•
•
Acidity, (as CaC03), Shake Extract
M2310 B
Alkalinity, Total (as CaC03), Shake Extract
M2320 B (1)
Mercury, Shake Extract
D3987/SW7470A
Metals, Shake Extract, by GFAA
03987/7000 G
Metals, Shake Extract, by ICP
D3987/6010B
Metals Analyses include: As, Ba, B, Cd, Cr, Co, Cu, Fe, Mn, Ni, Se, Ag, Zn, Be, Sb, Pb, Tl
Net Neutralization, Sluny
E670/2-74-70 N
Neutralization Potential, Sluny
E600/2-78-54 N
pH, Shake Extract
D3987/SW9040B
Phenols, Shake Extract
Shake Extraction (Inorganic)
(Phenol)
(Acidity/Alkalinity/pH)
D3987/SW9066
D3987
D3987
MaRyan Mining, LLC
Amalyses for Beneficial Use Criteria
ADM Fly Ash Results
Sample Collected 1/6/2015
Parameter
Fly Ash
ID:
1036
Alkalinity
2520
pH
12.7
Applicable Class I
Units
Groundwater
Units
Pass/Fail
0.1000
mg/1
Pass
Standard (620.410)
mg/1
< 0.005
mg/1
NP
289
CaC03 T/KT
NNP
289
CaC03 T/KT
Acidity
-2490
mg/1
Barium
0.202
mg/1
2.0000
mg/1
Pass
Beryllium
< 0.001
mg/1
0.0040
mg/1
Pass
Boron
Cadmium
0.264
2.0000
0.0050
mg/1
mg/1
Pass
< 0.002
mg/1
mg/1
Chromium
0.0583
mg/1
0.1000
mg/1
Pass
Cobalt
mg/1
1.0000
mg/1
Pass
mg/1
0.6500
mg/1
Pass
mg/1
5.0000
mg/1
Pass
mg/1
0.1500
mg/1
Pass
mg/1
0.1000
mg/1
Pass
Silver
< 0.010
< 0.010
< 0.020
< 0.005
< 0.010
< 0.010
mg/1
0.0500
mg/1
Pass
Zinc
0.0073
mg/1
5.0000
mg/1
Pass
Antimony
mg/1
0.0060
mg/1
Pass
Arsenic
< 0.001
< 0.001
mg/1
0.0100
mg/1
Pass
Lead
0.0026
mg/1
0.0075
mg/1
Pass
Selenium
0.010
mg/1
0.0500
mg/1
Pass
Thallium
< 0.001
mg/1
0.0020
mg/1
Pass
Mercury
< 0.0002
mg/1
0.0020
mg/1
Pass
Phenol
Copper
Iron
Manganese
Nickel
Pass
January 19,2015
Danielle Mullendore
Hanson Professional Services, Inc.
1525 South Sixth Street
Springfield, IL 62703
TEL; (217) 747-9375
FAX: (217) 788-5241
RE: 13E0032Gil 000
WorkOrder: 15010500
Dear Danielle Mullendore:
TEKLAB, JNC received 1 sample on 1/13/2015 1:55:00 PM for the analysis presented in the
following report.
Samples are analyzed on an as received basis unless otherwise requested and documented. The
sample results contained in this report relate only to the requested analytes of interest as
directed on the chain of custody. NELAP accredited fields of testing are indicated by the letters
NELAP under the Certification column. Unless otherwise documented within this report,
Teklab Inc. analyzes samples utilizing the most current methods in compliance with 40CFR.
All tests are performed in the Collinsville, IL laboratory unless otherwise noted in the Case
Narrative.
All quality control criteria applicable to the test methods employed for this project have been
satisfactorily met and are in accordance with NELAP except where noted. The following report
shall not be reproduced, except in full, without the written approval ofTeklab, Inc.
If you have any questions regarding these tests results, please feel free to call.
Sincerely,
MalVin L. Darling
Project Manager
(618)344-1004 ex 41
[email protected]
Page1 of6
Report Contents
htto: f fwww.teklabinc.com I
This reporting package includes tbe following:
Cover Letter
Report Contents
2
Definitions
3
Case Narratrva
4
Laboratory Results
5
6
Chain of Custody
Appended
Page2of'6
Definitions
Abbr Deimition
CCV Continuing calibration verification is a check of a standard to determine the state of calibration of an instrument between recalibration.
DF Dilution factor is the dilution performed during analysis only and does not take into account any dilutions made during sample preparation. The
reported result is final and includes all dilutions factors.
DNI Did not ignite
DUP Laboratory duplicate is an aliquot of a sample taken from the same container under laboratory conditions for independent processing and analysis
independently of the original aliquot.
JCV Initial calibration verification is a check of a standard to determine the state of calibration of an instrument before sample analysis is initiated.
IDPH IL Dept. of Public Health
LCS Laboratory control sample, spiked with verified known amounts of analytes, is analyzed exactly like a sample to establish intra-laboratory or analyst
specific precision and bias or to assess the performance
all or a portion of the measurement system. The acceptable recovery range is in the QC
of
LCSD Laboratory control sample duplicate is a replicate laboratory control sample that is prepared and analyzed in order to determine the precision of the
approved test method. The acceptable recovery range is listed in the QC Package (provided upon request).
MB Method blank is a sample of a matrix similar to the batch of associated sample (when available) that is free from the analytes of interest and is
processed simultaneously with and under the same conditions as samples through all steps of the analytical procedures, and in which no target
analytes or interferences should present at concentrations that impact the analytical results for sample analyses.
MDL Method detection limit means the minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte
concentration is greater than zero.
MS Matrix spike is an aliquot of matrix fortified (spiked) with known quantities of specific analytes that is subjected to the entire analytical procedures in
order to determine the effect of the matrix on an approved test method's recovery system. The acceptable recovery range is listed in the QC
MSD Matrix spike duplicate means a replicate matrix spike that is prepared and analyzed in order to determine the precision of the approved test method.
The acceptable recovery range is listed in the QC Package (provided upon request).
MW Molecular weight
NO Not Detected at the Reporting Umit
NELAP NELAP Accredited
PQL Practical quantitation limit means the lowest level that can be reliably achieved within specified limits of precision and accuracy during routine
laboratory operation conditions. The acceptable recovery range is listed in the QC Package (provided upon request).
RL The reporting limit the lowest level that the data is displayed in the final report. The reporting limit may vary according to customer request or sample
dilution. The reporting limit may not be less than the MDL
RPD Relative percent difference is a calculated difference between two recoveries {ie. MSIMSO). The acceptable recovery limit is listed in the QC
Package (provided upon request}.
SPK The spike is a known mass of target analyte added to a blank sample or sub-sc;~mple; used to determine recovery deficiency or for other quality
control purposes.
Surr St~rnogates are compounds which are similar to the analytes of interest in chemical composition and behavior in the analytical process, but which are
not normally found in environmental samples.
TNTC Too numerous to count ( > 200 CFU)
Qualifiers
#- Unknown hydrocarbon
B-
Analyte detected in associated Method Blank
E - Value above quantitation range
H-
Holding times exceeded
J - Analyte detected below quantitation limits
M - Manual Integration used to determine area response
NO -
Not Detected at the Reporting Limit
S - Spike Recovery outside recovery limits
R-
RPD outside accepted recovery limits
X- Value exceeds Maxlmum Contaminant Level
Page3of6
Case Narrative
http: I /www.teklabinc.com I
ReportDate: 19-Jan-15
Cooler Receipt Temp: 20.6 °C
Locations and Accreditations
Address
Phone
Fax
Email
Kansas City
Collinsville •.o\ir
3920 Pintail Dr
8421 Nieman Road
Springfield, IL 62711-9415
Lenex.a, KS 66214
(618) 344-1004
(217) 698-1004
(913) 541-1998
(618) 344-1004
(618) 344-1005
(217) 698-1005
(913) 541-1998
(618) 344-1005
[email protected]
[email protected]
[email protected]
[email protected]
Collinsviii.e
Springfield
State
Dept
Cert#
NELAP
ExpDate
Lab
illinois
!EPA
100226
NELAP
1131/2015
Collinsville
Karuias
KDHE
E-10374
NELAP
4'30/2015
Collinsville
Louisiana
LDEQ
!66493
NELAP
6/30/2015
Collinsville
Louisiana
LDEQ
166578
NELAP
6130/2015
Collinsville
Texas
TCEQ
Tl 04704515-12-1
NELAP
7!31/2015
Collinsville
Arkansas
ADEQ
88-0966
3/1412015
Collinsville
illinois
IDPH
17584
5/31/2015
Collinsville
Kentucky
KDEP
98005
l2/31/2015
Collinsville
Kentucky
UST
0073
1/31/2015
Colliusville
Missouri
MDNR
00930
5/31/2015
Collinsville
Oklahoma
ODEQ
9978
8l3JI2015
Collinsville
Page4of6
Laboratory Results
http:/twww.teklabinc.comf
Client Sample ID: Bed Ash (ID: 1002)
Lab ID: 15010500-001
Matrix: SOUD
Analyses
Collection Date: 01/08/2015 8:25
Certification
RL
Qual
Result
Units
DF
Date Analyzed Batch
ASTM D3987, STANDARD METHODS 231 0 B IN SHAKE EXTRACT
Acidity, Total (as CaC03)
-100000
-2250
mgfL
01/15/20151 1:51 R199788
2300
mg/L
01/15/2015 11:51 R199772
ASTM D3987, STANDARD METHODS 2320 BIN SHAKE EXTRACT
Alkalintty, Total (as CaC03)
0
ASTM 03987, SW-846 9040 B, IN SHAKE EXTRACT
pH
01/14/2015 20:31
12.7
105419
ASTM 03987, SW-846 9066, IN SHAKE EXTRACT
Phenol, SHAKE
< 0.005
0.005
mg!L
01/15/201 5 13:36 R199812
EPA 600/2-78-54 SLURRY
Neutralization Potential
0
433 CaC03T/KT
01/16/2015 8:00 R199873
0
433
CaC03 T/KT
01/1612015 8:00 R199874
EPA 670 2-74-70 SLURRY
Net Neutralization
ASTM 03987, SW-846 3005A, 601 OB, METALS IN SHAKE EXTRACT BY ICP
Barium
0.005
0.225
mg/L
01/15/2015 12:32 105444
Beryllium
Boron
0.001
0.02
< 0.001
mg/L
01/15/2015 12:32 105444
mg/L
Cadmil.lm
0.002
Chromium
0.01
0.364
< 0.002
0.0051
mg/L
01/15/201512:32 105444
01/15/2015 12:32 105444
Cobalt
0.01
< 0.01
mg/L
01/15/2015 12:32 105444
Copper
O.D1
< 0.01
Iron
0.02
< 0.02
< 0.005
< 0.01
< 0.01
mg!L
mg/L
mg!L
01/15/2015 12:32 105444
01/15/2015 12:32 105444
01/15/2015 12:32 105444
mg/L
01/15/2015 12:.32 105444
mg/L
01/15/2015 12:32 105444
0.0054
mg/L
01/15/2015 12:32 105444
ASTM D3987, SW-846 3005A, 6020A, METALS IN SHAKE EXTRACT BY ICPMS
Antimony
NELAP
0.001
< 0.001
Arsenic
NELAP
0.001
< 0.001
mg/L
5
01/15/2015 17:45 105445
mg!L
5
01/15/201517:45 105445
Manganese
Nickel
0.005
0.01
Silver
0.01
Zinc
0.01
Lead
Selenium
Thallium
NELAP
NELAP
NELAP
0.001
J
J
J
mg/L
01/15/2015 12:32 105444
1
0.0003
mg!L
5
01 /15/2015 17:45 105445
0.001
0.0031
mg/L
5
01/15/2015 17:45 105445
0.001
< 0.001
mgfL
5
01/15/2015 17:45 105445
0.0002
<0.0002
mg/L
ASTM D3987, SW-846 7470A IN SHAKE EXTRACT
Mercury, SHAKE
01/15/2015 11:02 105446
Page5oF6
http: I fwww.teklabinc.com l
Carrier: Kelly Klostermann
Received By: SRH
ReViewed by:
On:
Completed by:
On:
13-Jan-15
13-Jan-15
Emily E. Pohlman
Pages to follow:
Chain of custody
1
Shipping container/cooler in good condition?
Extra pages induded
Elizabeth A. Hurley
1
Yes D
None ~
Yes ~
Yes ~
Ice
NoD
Chain of custody agrees with sample labels?
Yes ~
NoD
Samples in proper container/bottle?
Yes
Sample containers intact?
Yes ~
Yes ~
Type of thermal preservation?
Chain of custody present?
Chain of custody signed when relinquished and received?
Sufficient sample volume for indicated test?
All samples received within holding lime?
0
Yes~
Reported field parameters measured:
Field0
Container/Temp Blank temperature in compliance?
Yes 0
Not Present
NoD
0
Blue ice
0
0
Temp 9 C
Dry Ice
20.6
D
NoD
NoD
NoD
NoD
NoD
NA0
Lab D
No~
When thermal presentation Is required, samples are comp#ant with a temperature between
0.1
6. O'C, or when samples are received on ice the same day as collected.
·c -
Water- at least one vial per sample has z:ero headspace?
Yes
Water - TOX containers have zero headspace?
Yes
NoVOA vials
0
0
No TOX containers ~
Water- pH acceptable upon receipt?
Yes D
NA
NPDES/CWA TCN interferences checked/treated in the field?
Yes 0
NA
0
0
Any No responses must be detailed below or on the COC.
The sample was out of temperature compfiance upon receipt. Danielle Mullendore was noiifred of this error via workorder summary.
Page6of6
CHAIN OF CUSTODY RECORD
Time
Collected
Sampler (signature):
Date
Collected
~ : z_r- '~-f"h. X
0
;;e;,s-
.g
.!!.,
~
X
~
CJl 0
Matrix
!~
0
Type
----~-------------------------
_!!!_aR_yan Mining LLC
CLIENT INFORMATION;
client
Address:
~· ~·
---
Hanson Professional Services Inc.
1525 South 6th Street
- Sprlii.gfield, Illinois 62703
Sample Description
Samp.ler (please print}:
SAMPLE INfORMATION:
.....,I!"\
1'5DJpSW
A-0\~-A':\'\ l\D: l5?~ ~}
.- .
--
~
~
-~
'E
0
...
u
.....0
1
'
~:
; ~
:~· ~~
'
q;
':.·\.
;
l~O\~D
~HANSON
Remarks
within holding time
in proper container
JJ: 3'l)Chilled (5.4QC)
Samples received:
Y
or N
o1NY
;('fJo~
'f!J
O(..V·
'L-. (o 0c) Yl-ill•.•L-
See attached. Routine turnarc und
Contact Name: Danielle Mullendore
Telephone No.: (217) 7 4 7-93 7 5
Fax No.:
(217) 788-2503
-13E0032G/ 1000
Project ID/PO:
fl>-v
Analyses
Desired
(l)f'l}
'<I
X
ate/ .Time
v11u' 11.1
~/Time
~~
1. '/. 1r- 13..55
Testing Sample Parameters
LRD Memorandum 95-8 (Beneficial Use)
•
Acidity, (as CaC03), Shake Extract
M231 0 B
Alkalinity, Total (as CaC03), Shake Extract
M2320 B (T)
Mercury, Shake Extract
D3987/SW7470A
Metals, Shake Extract, by GFAA
D3987/7000 G
Metals, Shake Extract, by ICP
D3987/6010B
Metals Analyses include: As, Ba, B, Cd, Cr, Co, Cu, Fe, Mn, Ni, Se, Ag, Zn, Be, Sb, Pb, 11
NetNeutralization, Slurry
E67012-74-70N
Neutralization Potential, Sluny
E600/2-78-54 N
pH, Shake Extract
D3987/SW9040B
Phenols, Shake Extract
D3987/SW9066
03987
•
(Phenol)
•
•
•
•
•
•
•
•
•
•
(Acidity/Alkalinity/pH)
D3987
MaRyan Mining, llC
Amalyses for Beneficial Use Criteria
ADM Bed Ash Results
Sample Collected 1/8/2015
Parameter
Bed Ash
10: 1002
Alkalinity
2300
pH
12.7
Phenol
Applicable Class I
Units
Groundwater
Units
Pass/Fail
0.1000
mg/1
Pass
2.0000
0.0040
mg/1
mg/i
Pass
2.0000
0.0050
0.1000
mg/1
mg/1
mg/1
1.0000
mg/1
Pass
Pass
Pass
Pass
Standard (620.410)
mg/1
< 0.005
mg/1
433
CaC03 T/KT
CaC03 T/KT
Acidity
433
-2250
Barium
0.225
mg/1
mg/1
mg/1
mg/1
Chromium
<0.001
0.364
< 0.002
0.0051
Cobalt
< 0.010
mg/1
mg/1
Copper
< 0.010
mg/1
0.6500
Iron
< 0.020
mg/1
5.0000
mg/1
mg/1
Manganese
mg/1
0.1500
mg/1
Pass
mg/1
0.1000
mg/1
Pass
Silver
< 0.005
< 0.010
< 0.010
mg/1
0.0500
mg/1
Pass
Zinc
0.0054
mg/1
5.0000
mg/1
Pass
Antimony
mg/1
0.0060
mg/1
Pass
Arsenic
< 0.001
< 0.001
mg/1
0.0100
mg/1
Pass
lead
0.0003
mg/1
0.0075
mg/1
Pass
Selenium
mg/1'
0.0500
mg/1
Pass
Thallium
0.0031
< 0.001
mg/1
0.0020
mg/1
Pass
Mercury
<0.0002
mg/1
0.0020
mg/1
Pass
NP
NNP
Beryllium
Boron
Cadmium
Nickel
mg/1
Pass
Pass
Pass
Calculation for Tons of Ash per 1000 Tons of Coarse Refuse to Achieve NNP
refuse
4.15% Pyritic Sulfur in Refuse
129.53 Potential Acidity (PA)
59.17 Neutralization Potential (NP)
-70.36 Net Neutralization Potential (NNP) (NNP = NP-PA)
Flvash
(tons per 1k tons of refuse)
ADM
0.00% Pyritic Sulfur in Flyash
289.00 Net Neutralization Potential (NNP} (NP-PA} (tons per 1,000 tons of refuse)
3.46 Multiplier for CaC03 adjustment
108.13 Tons of ash per 1,000 tons of refuse for each% of pyritic sulfur
Bedash
ADM
0.00% Pyritic Sulfur in Bedash
433.00 Net Neutralization Potential (NNP) (NP-PA) (tons per 1,000 tons of refuse)
72.17 Tons of ash per 1,000 tons of refuse for each% of pyritic sulfur
Ash Mix
70.4% Flyash
29.6% Bedash
331.62 Net Neutralization Potential (NNP) {NP-PA) (tons per 1,000 tons of refuse)
212.18
Tons of ash per 1,000 tons of refuse (Refuse N NP Adjusted for 2014)

Macoupin Energy, LLC - Illinois Environmental Protection Agency

Transcription

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